18488 Federal Register / Vol. 89, No. 50 / Wednesday, March 13, 2024 / Rules and Regulations 

1 In this document and the Report and Order, we 

use the term Commercial Mobile Radio Service 

(CMRS) provider to refer to providers of CMRS, as 

defined in 47 CFR 9.3 (‘‘Commercial mobile radio 

service (CMRS)’’). When addressing the record in 

this proceeding, we assume that commenters using 

terms such as ‘‘wireless carriers’’ or ‘‘wireless 

providers’’ refer to CMRS providers subject to part 

9 of the Commission’s rules. 

2The Commission defines real-time text as ‘‘[t]ext 

communications that are transmitted over internet 

Protocol (IP) networks immediately as they are 

created, e.g., on a character-by-character basis.’’ 47 

CFR 9.3; accord id. 67(g). In this document and the 

Report and Order, we use the term ‘‘RTT 

communications’’ to refer to instances in which an 

RTT user initiates contact with 911, for consistency 

with our part 9 and part 67 rules. See 47 CFR 

9.10(c), 67.1(g), 67.2(c)(2). When addressing the 

record in this proceeding, we assume that 

commenters using the terms ‘‘RTT call’’ or ‘‘RTT 

message’’ refer to the same RTT communications 

described in the Commission’s part 9 and part 67 

rules. 

3 Location-Based Routing for Wireless 911 Calls, 

PS Docket No. 18–64, Notice of Proposed 

Rulemaking, 37 FCC Rcd 15183, 15184, para. 1 

(2022), 88 FR 2565 (January 17, 2023) (notice of 

proposed rulemaking or NPRM). 

4The Commission has previously found that a 

one minute increase in response times increases 

mortality, and that a one minute decrease in 

response times decreases mortality. See, e.g., 

Wireless E911 Location Accuracy Requirements, 

Third Further Notice of Proposed Rulemaking, 29 

FCC Rcd 2374, 2388–89, para. 33 & n.70 (2014), 79 

FR 17820 (March 28, 2014). As stated in the notice 

of proposed rulemaking and affirmed in the Report 

and Order, the Commission estimates that the 

implementation of wireless location-based routing 

under the rules we adopt in this document will save 

13,837 lives annually, assuming a one-minute 

decrease in response time. See Notice of Proposed 

Rulemaking, 37 FCC Rcd at 15206–07, para. 61 & 

n.161. 

FEDERAL COMMUNICATIONS 

COMMISSION 

47 CFR Part 9 

[PS Docket No. 18–64; FCC 24–4; FR ID 

202993] 

Location-Based Routing for Wireless 

911 Calls 

AGENCY: Federal Communications 

Commission. 

ACTION: Final rule. 

SUMMARY: The Federal Communications 

Commission (the FCC or Commission) 

adopted a Report and Order in PS 

Docket No. 18–64, FCC 24–4, on January 

25, 2024, and released on January 26, 

2024. This document is a summary of 

the Commission’s Report and Order. 

The Report and Order adopted rules to 

more precisely route wireless 911 calls 

and Real-Time Texts (RTT) to Public 

Safety Answering Points (PSAPs), 

which can result in faster response 

times during emergencies. Wireless 911 

calls have historically been routed to 

PSAPs based on the location of the cell 

tower that handles the call. Sometimes, 

however, the 911 call is routed to the 

wrong PSAP because the cell tower is 

not in the same jurisdiction as the 911 

caller. This can happen, for instance, 

when an emergency call is placed near 

a county border. These misrouted 911 

calls must be transferred from one PSAP 

to another, which consumes time and 

resources and can cause confusion and 

delay in emergency response. The 

Report and Order requires wireless 

providers to deploy technology that 

supports location-based routing, a 

method that relies on precise 

information about the location of the 

wireless caller’s device, on their internet 

Protocol (IP)-based networks and to use 

location-based routing to route 911 

voice calls and RTT communications to 

911 originating on those networks when 

caller location is accurate and timely. 

The Report and Order provides six 

months for nationwide wireless 

providers to implement location-based 

routing for wireless 911 voice calls and 

provides 24 months for non-nationwide 

wireless providers to implement 

location-based routing of wireless 911 

voice calls. The Report and Order 

provides 24 months for all wireless 

providers to implement location-based 

routing for RTT communications to 911. 

DATES:

Effective date: May 13, 2024. 

Compliance date: Compliance will 

not be required for § 9.10(s)(4) and (5) 

until a document is published in the 

Federal Register announcing a 

compliance date and revising or 

removing § 9.10(s)(6). 

FOR FURTHER INFORMATION CONTACT: 

Rachel Wehr, Attorney Advisor, Policy 

and Licensing Division, Public Safety 

and Homeland Security Bureau, (202) 

418–1138, Rachel.Wehr@fcc.gov, or 

Brenda Boykin, Deputy Division Chief, 

Policy and Licensing Division, Public 

Safety and Homeland Security Bureau, 

(202) 418–2062, Brenda.Boykin@fcc.gov. 

SUPPLEMENTARY INFORMATION: This 

document is a summary of the 

Commission’s Report and Order. The 

full text of the Report and Order is 

available for public inspection at 

https://docs.fcc.gov/public/ 

attachments/FCC-24-4A1.pdf. To 

request materials in accessible formats 

for people with disabilities (Braille, 

large print, electronic files, audio 

format), or to request reasonable 

accommodations (e.g., accessible format 

documents, sign language interpreters, 

CART, etc.), send an email to fcc504@

fcc.gov or call the Consumer & 

Governmental Affairs Bureau at 202– 

418–0530 (voice). 

Congressional Review Act 

The Commission has determined, and 

the Administrator of the Office of 

Information and Regulatory Affairs, 

Office of Management and Budget, 

concurs, that this rule is major under 

the Congressional Review Act, 5 U.S.C. 

804(2). The Commission will send a 

copy of the Report and Order to 

Congress and the Government 

Accountability Office pursuant to 5 

U.S.C. 801(a)(1)(A). 

Synopsis 

I. Background 

1. This document is a summary of the 

Commission’s Report and Order. In this 

document, we require Commercial 

Mobile Radio Service (CMRS) 

providers 1 to implement location-based 

routing for wireless 911 voice calls and 

real-time text (RTT) communications 2

to 911 nationwide. With location-based 

routing (LBR) as implemented under 

these rules, CMRS providers will use 

precise location information to route 

wireless 911 voice calls and RTT 

communications to 911 to the 

appropriate public safety answering 

point (PSAP). For the millions of 

individuals seeking emergency 

assistance each year by wireless 911 

voice call or RTT communication to 

911, improving routing for these 

services will reduce emergency 

response times and save lives. 

2. In December 2022, the Commission 

adopted a notice of proposed 

rulemaking proposing to require CMRS 

providers and covered text providers to 

implement location-based routing for 

wireless 911 voice calls and texts 

nationwide.3 Public safety commenters 

overwhelmingly supported the 

Commission’s proposals. Legacy towerbased routing results in millions of 911 

voice calls nationwide arriving at the 

incorrect PSAP for the caller’s location, 

which can result in a delay of a minute 

or more in dispatch and response.4 The 

record confirms that implementing 

location-based routing is technologically 

feasible and will significantly reduce 

wireless 911 voice call transfers, saving 

valuable time for both PSAPs and 

callers. As a result of the location-based 

routing rules we adopt, millions more 

wireless 911 calls will reach the 

appropriate PSAP without the need for 

transfer or delay. 

3. To facilitate the implementation of 

location-based routing for wireless 911 

voice calls and RTT communications to 

911, we take the following actions: 

• We require CMRS providers to 

deploy location-based routing 

technology for wireless 911 voice calls 

and RTT communications to 911 on 

their internet Protocol (IP)-based 


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Federal Register / Vol. 89, No. 50 / Wednesday, March 13, 2024 / Rules and Regulations 18489 

5The Commission defines a ‘‘[n]on-nationwide 

CMRS provider’’ for purposes of its part 9 rules as 

‘‘[a]ny CMRS provider other than a nationwide 

CMRS provider.’’ 47 CFR 9.10(i)(1)(v). A 

‘‘[n]ationwide CMRS provider’’ for purposes of the 

Commission’s part 9 rules is ‘‘[a] CMRS provider 

whose service extends to a majority of the 

population and land area of the United States.’’ 47 

CFR 9.10(i)(1)(iv). 

6The Commission defines ‘‘covered text 

provider’’ as including ‘‘all CMRS providers as well 

as all providers of interconnected text messaging 

services that enable consumers to send text 

messages to and receive text messages from all or 

substantially all text-capable U.S. telephone 

numbers, including through the use of applications 

downloaded or otherwise installed on mobile 

phones.’’ 47 CFR 9.10(q)(1). 

7See Facilitating Implementation of Next 

Generation 911 Services (NG911), PS Docket No. 

21–479, Notice of Proposed Rulemaking, FCC 23– 

47, 2023 WL 3946685 (June 9, 2023), 88 FR 43514 

(July 10, 2023), https://www.fcc.gov/document/fccproposes-action-expedite-transition-nextgeneration-911-0 (NG911 Notice of Proposed 

Rulemaking). 

8 Location-Based Routing for Wireless 911 Calls, 

PS Docket No. 18–64, Notice of Inquiry, 33 FCC Rcd 

3238, 3240, para. 6 (2018) (Notice of Inquiry). 

9Notice of Proposed Rulemaking, 37 FCC Rcd at 

15185–86, para. 7. For example, a cell tower in 

Northern Virginia may pick up a wireless 911 voice 

call originating in Washington, DC, but route the 

call to a Virginia PSAP. Id. 

10Alliance for Telecommunications Industry 

Solutions (ATIS), Analysis of Predetermined Cell 

Sector Routing Outcomes Compared to Caller’s 

Device Location, ATIS–0500039 at 4 (July 2, 2019), 

https://access.atis.org/apps/group_public/ 

document.php?document_id=48697 (ATIS– 

0500039). Intrado cites a 2018 study concluding 

that 12.96% out of a set of five million wireless 911 

calls were misrouted. Intrado Life & Safety, Inc. 

(Intrado) Public Notice Comments at 3 & n.8, 4 (rec. 

July 11, 2022) (Intrado PN Comments). 

11For example, the Fayetteville (Arkansas) Police 

Department reports that ‘‘roughly 30% or more’’ of 

the 911 calls its jurisdiction receives are misrouted 

from neighboring jurisdictions. Natisha Claypool, 

Assistant Dispatch Manager, Fayetteville Police 

Department Public Notice Comments (rec. July 11, 

2022). Intrado estimates, based on data collected in 

AT&T’s pilot implementation of location-based 

routing in February/March 2022, that Palm Beach 

County, Florida, was experiencing misrouted calls 

with tower-based routing at a rate of at least 11%, 

and as high as 20–50% along PSAP boundaries. 

Intrado PN Comments at 4–5. 

12 In the Commission’s 2023 annual 911 fee 

report, respondents reported receiving a combined 

total of approximately 158 million wireless 911 

voice calls in calendar year 2022. FCC, Fifteenth 

Annual Report to Congress on State Collection and 

Distribution of 911 and Enhanced 911 Fees and 

Charges at 16, Table 3 (2023), https://www.fcc.gov/ 

general/911-fee-reports (Fifteenth Annual 911 Fee 

Report). Assuming 12% of these calls were 

misrouted, misroutes would total nearly 19 million 

calls. NENA: The 9–1–1 Association (NENA) 

estimates that 23 million wireless 911 voice calls 

are misrouted annually. NENA Notice of Proposed 

Rulemaking Comments at 2 (rec. Feb. 15, 2023) 

(NENA NPRM Comments). 

13See, e.g., Association of Public-Safety 

Communications Officials International, Inc. 

(APCO) Public Notice Comments at 2 (rec. July 11, 

2022) (APCO PN Comments) (noting that ‘‘it’s 

possible that a misrouted call will introduce a delay 

of a minute or longer’’); NENA Public Notice 

Comments at 4 (rec. July 11, 2022) (‘‘[T]he general 

anecdotal consensus was that a call transfer 

typically takes ‘about a minute.’ ’’); Peninsula Fiber 

Network Public Notice Comments at 1 (rec. July 8, 

2022) (‘‘Each transfer takes between 15 to 90 

seconds to set up and complete.’’). 

networks (i.e., 4G LTE, 5G, and 

subsequent generations of IP-based 

networks). We also require CMRS 

providers to use location-based routing 

to route wireless 911 voice calls and 

RTT communications to 911 originating 

on their IP-based networks when 

location information meets certain 

thresholds for accuracy and timeliness. 

• We require CMRS providers to use 

location-based routing for wireless 911 

voice calls and RTT communications to 

911 when caller location information 

available to the CMRS provider’s 

network at time of routing is 

ascertainable within a radius of 165 

meters at a confidence level of at least 

90%. In the absence of these conditions, 

CMRS providers must use alternative 

routing methods based on ‘‘best 

available’’ location information, which 

may include but is not limited to 

device-based or tower-based location 

information. 

• We adopt the proposed six-month 

timeline for nationwide CMRS 

providers to implement location-based 

routing for wireless 911 voice calls and 

provide twenty-four months for nonnationwide CMRS providers to 

implement location-based routing of 

wireless 911 voice calls.5 In addition, 

we provide 24 months for all CMRS 

providers to implement location-based 

routing for RTT communications to 911. 

• We require CMRS providers within 

60 days of the applicable compliance 

deadlines to certify and submit evidence 

of compliance with location-based 

routing requirements. At that time, 

CMRS providers also must submit onetime live call data reporting on the 

routing methodologies for calls in live 

call areas, and they must certify the 

privacy of location information used for 

location-based routing. 

• We defer consideration of proposals 

in the notice of proposed rulemaking to 

require CMRS providers and covered 

text providers 6 to implement locationbased routing for Short Message Service 

(SMS) texts to 911. 

• We defer consideration of proposals 

and issues raised in the notice of 

proposed rulemaking concerning IPformatted delivery of wireless 911 voice 

calls, texts, and associated routing 

information for consideration in the 

Commission’s pending Next Generation 

911 (NG911) Transition docket (PS 

Docket No. 21–479—Facilitating 

Implementation of Next Generation 911 

Services).7

4. Legacy Enhanced 911 Routing. 

When the first 911 call was placed in 

1968, 911 service was provided to the 

public over wireline telephone 

networks, and wireline providers used 

the fixed location of the calling 

telephone to route 911 calls to the 

nearest PSAP.8 With the deployment of 

the first generation of cellular service, 

wireless 911 voice calls could originate 

from any location served by the wireless 

network, and the caller could move 

locations during the call. To enable 

timely routing of wireless 911 voice 

calls, CMRS providers typically 

programmed their networks to use the 

location of the first cell tower receiving 

the call to determine the nearest PSAP 

and route the call accordingly. This 

became the basis for routing of wireless 

Enhanced 911 (E911) calls (legacy E911 

routing). 

5. Wireless 911 Voice Call Misroutes. 

Technical limitations of legacy E911 

routing can result in a CMRS provider 

routing a wireless 911 voice call to a 

PSAP other than the one designated by 

the relevant state or local 911 authority 

to receive 911 calls from the caller’s 

actual location.9 The Commission 

considers wireless 911 voice calls 

routed to a PSAP other than the one 

designated for the caller’s location to be 

‘‘misrouted,’’ although such misroutes 

generally result from tower-based call 

routing mechanisms working as 

designed, not from technical failure of 

those mechanisms. The Alliance for 

Telecommunications Industry Solutions 

(ATIS) estimates that on average 12% of 

wireless legacy E911 voice calls 

nationwide are misrouted.10 Other 

commenters indicate that the percentage 

of misrouted wireless 911 voice calls is 

higher in some jurisdictions.11 These 

estimates support the conclusion that 

tower-based routing causes millions of 

wireless 911 voice calls to be misrouted 

annually.12

6. When a wireless 911 voice call is 

misrouted, the answering 

telecommunicator must transfer the call 

to the PSAP that has jurisdiction to 

dispatch aid to the 911 caller’s location. 

This process consumes time and 

resources for both the transferring PSAP 

and the receiving PSAP and delays the 

dispatch of first responders to render 

aid. Commenters submit anecdotal 

evidence that a typical misroute 

introduces a delay of about a minute.13

NENA estimates that call transfers 

consume over 200,000 hours per year of 

excess 911 professional labor. Misrouted 

wireless 911 voice calls can also 

contribute to confusion and delay in 


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18490 Federal Register / Vol. 89, No. 50 / Wednesday, March 13, 2024 / Rules and Regulations 

14For example, on June 4, 2020, 16-year-old Fitz 

Thomas drowned at Confluence Park on the 

Potomac River, which separates Loudoun County, 

Virginia, and Montgomery County, Maryland. Press 

Release, Loudoun County Office of the County 

Administrator, Public Affairs and Communications, 

Loudoun County Releases Significant Incident 

Review of Goose Creek Drowning at 1 (Aug. 31, 

2020), https://www.loudoun.gov/ArchiveCenter/ 

ViewFile/Item/10062. Due to the incident’s 

proximity to the jurisdictional border of the 

Potomac River and the use of legacy E911 routing, 

both counties received wireless 911 calls routed 

from the park located on the Virginia side of the 

river. Id. at 2. Efforts to determine Thomas’s actual 

location contributed to a delay in dispatching first 

responders. Id. On July 15, 2022, Ma Kaing was shot 

and killed by a stray bullet outside her home in the 

East Colfax neighborhood of Denver. Jennifer 

Kovaleski, Stuck on the line: Cellphone calls routed 

to the wrong 911 center are costing life-saving 

seconds, Denver7 (Nov. 19, 2022), https://

www.denver7.com/news/investigations/stuck-onthe-line-cellphone-calls-routed-to-the-wrong-911- 

center-are-costing-life-saving-seconds. The news 

media reported that four calls from her family and 

neighbors were misrouted to a neighboring PSAP 

and required transfer; three callers hung up after 

waiting minutes on hold. Id. 

15The news media have widely reported on such 

tragic occurrences. For example, in December 2015, 

dispatchers were unable to locate Shanell 

Anderson, who drowned after accidentally driving 

off the road and into a pond close to the line 

between Fulton and Cherokee Counties in Georgia. 

Brendan Keefe and Phillip Kish, Lost on the Line: 

Why 911 is broken, 11ALIVE (Aug. 12, 2019), 

https://www.11alive.com/article/news/local/lost-onthe-line-why-911-is-broken/85-225104578. 

According to the news media, Shanell Anderson 

was able to call 911, but the call was picked up by 

a cell tower in Fulton County and routed to that 

county’s PSAP, where critical minutes were lost 

while dispatchers sought to determine the county 

in which she was located (Cherokee County). Id. In 

another incident in 2008, Olidia Kerr Day made a 

wireless 911 call before she was fatally shot in a 

murder-suicide in front of the Plantation, Florida, 

police department. Sofia Santana, Cell Phone 911 

Calls Are Often Routed to the Wrong Call Centers, 

Sun Sentinel (June 21, 2008), https://www.sunsentinel.com/sfl-flbsafe911calls0621sbjun21- 

story.html. According to the news media, although 

she placed the call in Plantation, the call was 

routed to the 911 center in Sunrise, Florida, and 

had to be transferred to Plantation. Id. 

16Commenters to the Notice of Inquiry offered 

varying opinions about whether technologies were 

capable of location-based routing without delaying 

911 calls. See, e.g., AT&T Notice of Inquiry Reply 

at 11 (rec. June 28, 2018) (‘‘Even the most promising 

of location-based technologies . . . have limits.’’); 

Motorola Solutions, Inc. Notice of Inquiry 

Comments at 2 (rec. May 7, 2018) (asserting that 

testing has confirmed that location-based wireless 

routing is faster and more accurate than legacy 

wireless routing). 

17 Federal Communications Commission Seeks to 

Refresh the Record on Location-Based Routing for 

Wireless 911 Calls, PS Docket No. 18–64, Public 

Notice, 37 FCC Rcd 7196, 7196 (2022) (Public 

Notice). 

18 Device-based hybrid (DBH) location is an 

estimation method that typically utilizes either a 

selection or a combination of location methods 

available to the handset in a given environment, 

including crowd-sourced Wi-Fi, A–GNSS, and 

possibly other handset-based sensors. Public Notice, 

37 FCC Rcd at 7197–98 n.8 (citing CSRIC V LBR 

Report at 16). It also includes an associated 

uncertainty estimate reflective of the quality of the 

returned location. Id. 

19A ‘‘911 text message’’ is ‘‘a message, consisting 

of text characters, sent to the short code ‘911’ and 

intended to be delivered to a PSAP by a covered 

text provider, regardless of the text messaging 

platform used.’’ 47 CFR 9.10(q)(9). The 

Commission’s text-to-911 rules are technology 

neutral and apply to both Short Message Service 

(SMS) and real-time text (RTT). Transition from 

TTY to Real-Time Text Technology; Petition for 

Rulemaking to Update the Commission’s Rules for 

Access to Support the Transition from TTY to RealTime Text Technology, and Petition for Waiver of 

Rules Requiring Support of TTY Technology, CG 

Docket No. 16–145, GN Docket No. 15–178, Report 

and Order, 31 FCC Rcd 13568, 13593, para. 45 

n.181 (2016), 82 FR 7699 (January 23, 2017) (RTT 

Order). RTT transition obligations only apply to a 

subset of covered text providers: ‘‘those entities that 

are involved in the provision of IP-based wireless 

voice communication service, and only to the 

extent that their services are subject to existing TTY 

technology support requirements under Parts 6, 7, 

14, 20, or 64 of the Commission’s rules.’’ RTT 

Order, 31 FCC Rcd at 13576–77, para. 12. 

20Notice of Proposed Rulemaking, 37 FCC Rcd at 

15184–85, para. 3. In the notice of proposed 

rulemaking, the Commission used the term 

‘‘NG911-capable’’ to refer to PSAPs or jurisdictions 

that have implemented IP-based network and 

software components that are capable of supporting 

the provision of NG911, including but not limited 

to an Emergency Services internet Protocol Network 

(ESInet). Id. at 15184, para. 3 n.5. NG911 relies on 

IP-based architecture rather than the Public 

Switched Telephone Network (PSTN)-based 

architecture of legacy 911 to provide an expanded 

array of emergency communications services that 

encompasses both the core functionalities of legacy 

E911 and additional functionalities that take 

advantage of the enhanced capabilities of IP-based 

devices and networks. Framework for Next 

Generation 911 Deployment, PS Docket No. 10–255, 

Notice of Inquiry, 25 FCC Rcd 17869, 17877, para. 

18 (2010), 76 FR 2297 (January 13, 2011). NG911 

architecture also provides for transitional network 

components to enable delivery of legacy 911 calls 

to ESInets during the transition to full end-state 

NG911. See id. at 17878, para. 20 (explaining that 

emergency calls can be delivered to ESInets from 

legacy networks). 

emergency response.14 This delay can 

have deadly consequences.15

7. Location-Based Routing Notice of 

Inquiry. In 2018, the Commission 

released a Notice of Inquiry seeking 

comment on issues related to misrouted 

wireless 911 calls, including the 

feasibility of location-based routing. 

Historically, generating precise caller 

location information typically required 

too much time to be used for 911 call 

routing. The Commission noted, 

however, that then-recent advances in 

location technology suggested it was 

feasible to pinpoint a wireless 911 voice 

caller’s location quickly enough to 

support an initial routing determination. 

The Commission also found that many 

location-based routing methods were 

promising. The record received in 

response to the Notice of Inquiry 

confirmed the emergence of potential 

location-based routing solutions but also 

indicated uncertainty about the 

capabilities of such solutions at the 

time.16

8. Location-Based Routing Public 

Notice. In June 2022, the Commission 

released a Public Notice to refresh the 

record on location-based routing 

developments since the Notice of 

Inquiry.17 Commenters confirmed that 

continued reliance on legacy E911 

routing methodology results in a 

considerable number of wireless 911 

voice call misroutes, which imposes 

significant burdens on public safety. 

Public safety commenters agreed that 

early location-based routing 

implementations by CMRS providers 

had shown that the technology was now 

technologically feasible. Several 

commenters noted that device-based 

hybrid (DBH) location technologies 18

were widely available on mobile devices 

and could be used for routing a high 

percentage of wireless 911 voice calls. 

9. Location-Based Routing Notice of 

Proposed Rulemaking. On December 22, 

2022, the Commission adopted the 

notice of proposed rulemaking in this 

proceeding, which proposed rules for 

CMRS and covered text providers to 

implement location-based routing for 

wireless 911 voice calls and 911 texts 19

nationwide, including wireless 911 

voice calls and 911 text messages 

originating in legacy, transitional, and 

NG911-capable public safety 

jurisdictions.20 The Commission 

proposed to establish requirements with 

respect to the accuracy and timeliness of 

location information CMRS and covered 

text providers would use to comply 

with location-based routing 

requirements. In particular, the 

Commission proposed to require CMRS 

providers and covered text providers to 

use location-based routing for 911 calls 

and texts when they have location 

information that meets the following 

specifications for timeliness and 

accuracy: (i) the information must be 

available to the provider network at the 

time the call or text is routed, and (ii) 

the information must identify the 

caller’s horizontal location within a 

radius of 165 meters at a confidence 

level of at least 90%. 

10. The Commission also proposed 

that when location information does not 

meet one or both of these requirements, 

CMRS providers and covered text 

providers would be required to route 

911 calls and texts based on the best 

available location information, which 

could include cell tower coordinates. In 

addition, to help ensure that public 

safety jurisdictions transitioning to 

NG911 could realize the benefits of 

location-based routing in an efficient 

and cost-effective manner, the 

Commission proposed to require CMRS 

providers and covered text providers to 

deliver wireless 911 voice calls, texts, 


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Federal Register / Vol. 89, No. 50 / Wednesday, March 13, 2024 / Rules and Regulations 18491 

21 In NG911 architecture, device-based location 

information embedded in IP-formatted 911 calls is 

first used by the provider to route the call to an 

ESInet, and the ESInet operator then applies NG911 

network routing policies to the embedded 

information to route the call to the appropriate 

PSAP. Notice of Proposed Rulemaking, 37 FCC Rcd 

at 15203, para. 53. 

22While the Commission has not specifically 

defined the term ‘‘911 authorities’’ in this 

proceeding, we use this term in this document to 

generally mean ‘‘[t]he state, territorial, regional, 

Tribal, or local agency or entity with the authority 

and responsibility under applicable law to 

designate the point(s) to receive emergency calls.’’ 

NG911 Notice of Proposed Rulemaking at *21, para. 

53 (proposing a definition of the term ‘‘911 

Authority’’ that would define the term for purposes 

of Commission rules related to the NG911 

transition). 

23Press Release, T-Mobile USA, Inc. (T-Mobile), 

T-Mobile First to Roll Out Cutting-Edge 911 

Capabilities (Dec. 17, 2020), https://www.tmobile.com/news/network/tmobile-next-generation911-location-based-routing (T-Mobile Dec. 17, 2020 

Press Release); T-Mobile Public Notice Reply at 2 

& n.6 (rec. July 25, 2022) (T-Mobile PN Reply); 

AT&T PN Comments at 4; CB Cotton, Verizon plans 

to update 911 routing technology after Denver’s East 

Colfax neighborhood calls for change, Denver7 

(Aug. 5, 2022), https://www.denver7.com/news/ 

local-news/verizon-plans-to-update-911-routingtechnology-after-denvers-east-colfax-neighborhoodcalls-for-change. 

24APCO NPRM Comments at 2; Adams County et 

al. NPRM Comments at 3; Boulder Regional 

Emergency Telephone Service Authority (BRETSA) 

Notice of Proposed Rulemaking Reply at 6 (rec. 

Mar. 20, 2023) (BRETSA NPRM Reply); Intrado 

NPRM Comments at 5; see also AT&T NPRM 

Comments at 4 (supporting a definition of ‘‘devicebased location information’’ that is tied to 

timeliness and accuracy metrics ‘‘that the 

Commission believes would represent a significant 

improvement over cell-based routing 

methodologies’’). 

25Letter from Christiaan Segura, Director, 

Regulatory Affairs, CTIA—The Wireless Association 

(CTIA), to Marlene H. Dortch, Secretary, FCC, PS 

Docket No. 18–64, at 2 (filed July 3, 2023) (CTIA 

July 3, 2023 Ex Parte); Intrado NPRM Comments at 

2, 5–6; Texas 9–1–1 Entities NPRM Comments at 5– 

6 n.21; NENA NPRM Reply at 4–5; Verizon Notice 

of Proposed Rulemaking Reply at 4–5 (rec. Mar. 20, 

2023) (Verizon NPRM Reply) (recommending the 

Commission ‘‘coupl[e] LBR with a framework for i3- 

based NG911 implementation’’); see also Letter 

from Joely Denkinger, Regulatory Counsel, Federal 

Affairs, GCI Communication Corp. (GCI), to Marlene 

H. Dortch, Secretary, FCC, PS Docket Nos. 18–64, 

21–479, at 1 (filed July 17, 2023) (GCI July 17, 2023 

Ex Parte). 

26Press Release, CTIA, Wireless Industry 

Announces Development in Improving 9–1–1 

Location Accuracy (Sept. 5, 2018), https://

www.ctia.org/news/wireless-industry-announcesdevelopment-in-improving-9-1-1-location-accuracy; 

Letter from Paul Margie, Counsel, Apple Inc., to 

Marlene H. Dortch, Secretary, FCC, PS Docket No. 

18–64 et al., at 2 (filed Sept. 24, 2019) (Apple Sept. 

24, 2019 Ex Parte). Device-based hybrid (DBH) 

location is ‘‘[a]n estimation method that typically 

utilizes either a selection or a combination of 

location methods available to the handset in a given 

environment—including crowd-sourced Wireless 

Fidelity (Wi-Fi), Assisted-Global Navigation 

Satellite System (A–GNSS), and possibly other 

handset-based sensors.’’ ATIS–0700042 at 2. ‘‘It also 

includes an associated uncertainty estimate 

reflective of the quality of the returned location.’’ 

Id. 

27ATIS–0700042; ATIS–0500039. ATIS observed 

that calls that are ‘‘sub-optimally routed’’ tend to 

occur ‘‘[a]long PSAP boundaries,’’ ‘‘[i]n areas 

having a dense concentration of PSAPs,’’ ‘‘[a]round 

major water features,’’ and ‘‘[a]long narrow strips of 

jurisdictional territory.’’ ATIS–0500039 at 12. 

28ATIS–0700042 at 22. CSRIC is a Federal 

advisory committee subject to the requirements of 

the Federal Advisory Committee Act (FACA), 5 

U.S.C. App. 2, and charged with providing 

recommendations to the Commission to ensure, 

among other things, the security and reliability of 

communications systems. FCC, Communications 

Security, Reliability, and Interoperability Council, 

https://www.fcc.gov/about-fcc/advisorycommittees/communications-security-reliabilityand-interoperability-council-0 (last visited Jan. 17, 

2023). 

and location information for routing 21

in IP format upon request of 911 

authorities 22 who have established the 

capability to accept NG911-compatible 

IP-based 911 communications. At the 

time of the notice of proposed 

rulemaking, AT&T, T-Mobile, and 

Verizon had stated publicly in the 

record or elsewhere that they had 

deployed or planned to deploy locationbased routing to some extent on their 

networks for voice calls.23 The 

Commission received twenty-six 

comments, fourteen replies, and several 

ex parte filings. 

11. Virtually all public safety 

commenters and some additional 

commenters support Commission action 

to require CMRS providers to 

implement location-based routing for 

wireless 911 voice calls. Multiple public 

safety commenters and Intrado support 

the Commission’s proposal that CMRS 

providers implement location-based 

routing nationwide. Commenters 

representing wireless interests urge the 

Commission to allow CMRS providers 

to implement location-based routing 

voluntarily or on a PSAP-by-PSAP basis, 

as opposed to a nationwide mandate. 

With respect to text-to-911, numerous 

commenters support requiring covered 

text providers to implement locationbased routing, but some commenters 

contend that such a requirement would 

be premature. Citing a lack of technical 

standards for routing SMS texts to 911, 

NENA, ATIS, and Southern Linc oppose 

requiring covered text providers to 

implement location-based routing for 

SMS but suggest that the Commission 

should require location-based routing 

for IP-based text solutions such as RTT. 

12. In response to the Commission’s 

proposed timeliness and accuracy 

requirements for use of location-based 

routing, some commenters express 

support for the proposed 

requirements,24 while others oppose the 

proposed accuracy threshold and 

request flexibility for providers to set 

their own thresholds. In response to the 

Commission’s proposed requirement for 

CMRS and covered text providers to 

deliver 911 calls, texts, and associated 

routing information in IP format upon 

request of 911 authorities who have 

established the capability to accept such 

communications, multiple commenters 

ask the Commission to address such 

proposals together with corresponding 

proposed requirements for other types 

of originating service providers in a 

separate proceeding.25

13. NG911 Notice of Proposed 

Rulemaking. In June 2023, the 

Commission adopted a notice of 

proposed rulemaking in PS Docket No. 

21–479 to advance the nationwide 

transition to Next Generation 911 

(NG911 Notice of Proposed 

Rulemaking). In the NG911 Notice of 

Proposed Rulemaking, the Commission 

proposed to require wireline, 

interconnected Voice over internet 

Protocol (VoIP), and internet-based 

Telecommunications Relay Service 

(TRS) providers to complete all 

translation and routing to deliver 911 

calls, including associated location 

information, in the requested IP-based 

format to an Emergency Services IP 

network (ESInet) or other designated 

point(s) that allow emergency calls to be 

answered, upon request of 911 

authorities who have certified the 

capability to accept IP-based 911 

communications. This proposal is 

similar to that proposed for CMRS and 

covered text providers in the notice of 

proposed rulemaking in this proceeding. 

14. Ongoing Location-Based Routing 

Deployment. As the Commission noted 

in the notice of proposed rulemaking, 

several developments indicate that 

location-based routing has become a 

viable methodology for CMRS providers 

to route wireless 911 voice calls and 

texts. These developments include 

studies on misroutes and location-based 

routing technology and increased 

deployment of DBH location 

technologies on consumer handsets.26

In 2019, ATIS published two studies on 

legacy E911 misroutes and the 

feasibility of location-based routing.27 In 

those studies, ATIS concluded that 

‘‘location-based routing is technically 

feasible within the timing 

considerations recommended by 

[Communications Security, Reliability, 

and Interoperability Council (CSRIC)] 

V’’ 28 and evaluated where ‘‘sub-optimal 

routing’’ occurred for a sample set of 

wireless emergency calls. ATIS has also 

issued two standards that support 

location-based routing: ATIS–0700042 

(Enhancing Location-Based Routing of 

Emergency Calls) and ATIS–0700015 

(ATIS Standard for Implementation of 

3GPP Common IMS Emergency 

Procedures for IMS Origination and 

ESInet/Legacy Selective Router 


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29CCA NPRM Comments at 7. CCA also states 

that ‘‘3GPP has also addressed how to implement 

location-based routing, and several 3GPP 

specifications relate to location services and 

emergency calling.’’ CCA NPRM Comments at 9. In 

particular, CCA identifies TS 23.167, entitled 

‘‘Technical Specification Group Services and 

System Aspects; IP Multimedia Subsystem (IMS) 

emergency sessions,’’ as identifying ‘‘architectural 

principles, location information principles, a 

reference architecture, functional descriptions, 

procedures for establishing an IMS emergency 

session, call flows, and related information.’’ Id. 

CCA also notes that other 3GPP specifications, 

including TS 36.305—‘‘Stage 2 functional 

specification of User Equipment (UE) positioning in 

E–UTRAN’’ and TS 38.305—‘‘NG Radio Access 

Network (NG–RAN); Stage 2 functional 

specification of User Equipment (UE) positioning in 

NG–RAN,’’ provide additional pertinent 

information regarding the implementation of 

location services data. Id. at 9–10. 

30AT&T PN Comments at 4; AT&T NPRM 

Comments at 1. AT&T notes that a few PSAPs are 

using unique internal routing solutions and that the 

company is working to ensure that its 

implementation of location-based routing meets the 

needs of these PSAPs. AT&T PN Comments at 4 n.3. 

31Letter from Eric Hagerson, Government Affairs 

Director, Public Safety and Security, T-Mobile, to 

Marlene H. Dortch, Secretary, FCC, PS Docket No. 

18–64 at 1 (filed Dec. 21, 2023) (T-Mobile Dec. 21, 

2023 Ex Parte). T-Mobile reports that it only 

deploys location-based routing in response to a 

PSAP’s request. See, e.g., T-Mobile Public Notice 

Comments at 1, 4–7 (rec. July 11, 2022) (T-Mobile 

PN Comments); T-Mobile PN Reply at 2–4. For 

context, the latest NENA data indicate that 5,748 

PSAPs operate in the United States. NENA, 9–1–1 

Statistics, https://www.nena.org/page/911Statistics 

(last visited Jan. 17, 2024). 

32Letter from Kristine Laudadio Devine, Counsel 

to T-Mobile USA, Inc., HWG LLP, to Marlene H. 

Dortch, Secretary, FCC, P.S. Docket Nos. 18–64, 21– 

479, at 1 (filed July 26, 2023) (T-Mobile July 26, 

2023 Ex Parte). For purposes of this document, we 

assume that when commenters specify an 

uncertainty measurement for an implementation of 

location-based routing, that they are referring to the 

radius in meters from the reported position at the 

same confidence level. This assumption is 

consistent with prior Commission discussion of 

confidence and uncertainty data in the Wireless 

Location Accuracy proceeding, i.e., that the 

uncertainty statistical estimate is expressed as a 

radius in meters around the reported position, and 

the confidence level is expressed as a percentage, 

indicating the statistical probability that the caller 

is within the area defined by the uncertainty. See, 

e.g., Wireless E911 Location Accuracy 

Requirements, Fourth Report and Order, PS Docket 

No. 07–114, 30 FCC Rcd 1259, 1326–27, para. 182 

n.458 (2015), 80 FR 11806 (March 4, 2015). 

33 In the Commission’s 2023 annual 911 fee 

report, respondents reported receiving a combined 

total of 824,609 texts to 911 in comparison to 

157,999,298 wireless 911 voice calls reported by 

respondents in calendar year 2022. Fifteenth 

Annual 911 Fee Report at 13–16, Table 3. 

34AT&T PN Comments at 5. AT&T explains that 

‘‘[w]hen the SMS message arrives at the TCC, [the 

TCC] queries [AT&T’s] wireless network for 

commercial location estimates to deliver the text 

message to the appropriate PSAP.’’ Id. 

35T-Mobile July 26, 2023 Ex Parte at 3. T-Mobile 

explains that texts to 911 are routed from TMobile’s network to its TCC vendor and, ‘‘whenever 

possible,’’ T-Mobile includes device-based hybrid 

location information with those texts. Id. 

36 Verizon Dec. 7, 2023 Ex Parte at 1. Verizon 

states that its location-based routing 

implementation will support location-based routing 

for RTT. Verizon NPRM Comments at 5. 

37RTT Order, 31 FCC Rcd at 13591–92, para. 43. 

This includes the requirement to deliver RTT 

communications within six months to PSAPs that 

submit a valid request. Id. at 13592–93, para. 45 & 

n.181. 

Termination). The Competitive Carriers 

Association (CCA) states that in these 

and other documents, ‘‘ATIS has 

defined several architecture options that 

carriers can use to provide locationbased routing as well as several call 

flow options from which carriers can 

choose to employ to conduct locationbased routing.’’ 29

15. The three nationwide CMRS 

providers are continuing to deploy 

location-based routing for wireless 911 

voice calls on their networks. AT&T 

completed the rollout of location-based 

routing on its network in June 2022 and 

uses location-based routing to deliver 

wireless 911 voice calls to nearly all 

PSAPs nationwide, regardless of 

whether such PSAPs support legacy 

E911 or are transitioning to NG911.30 TMobile launched location-based routing 

on its network in the states of Texas and 

Washington in 2020 and as of December 

2023 had deployed location-based 

routing for wireless 911 voice calls to 

1,591 PSAPs with an additional 596 in 

progress.31 In December 2023, Verizon 

reported that it had implemented 

location-based routing for wireless 911 

voice calls to 414 PSAPs with an 

additional 277 PSAPs in progress. 

16. For wireless 911 voice calls, 

AT&T, T-Mobile, and Verizon have, to 

date, implemented their own different 

thresholds to determine whether device 

location information arriving with the 

call is sufficiently precise for routing. 

According to Intrado, AT&T’s locationbased routing solution uses a threshold 

with a radius of 165 meters and 90% 

confidence, which has enabled AT&T to 

use location-based routing for over 80% 

of all wireless 911 voice calls on its 

network. T-Mobile reports that it has 

implemented ‘‘a location estimate 

uncertainty threshold for LBR currently 

set to 300 meters with a confidence 

level of 90%,’’ and reports that more 

than 95% of location estimates available 

at call routing fall within these 

metrics.32 Verizon reports that it uses 

‘‘an accuracy threshold of 200 meters 

maximum horizontal uncertainty with 

confidence of 90 percent.’’ AT&T, TMobile, and Verizon state that they 

default to legacy E911 routing when 

device location information arriving 

with the call exceeds the radius of the 

providers’ respective thresholds. 

17. Text Messaging Platforms. Since 

2014, all CMRS providers and covered 

text providers have been required to 

support delivery of 911 texts to PSAPs 

that are capable of receiving them. 

While availability of text-to-911 has 

increased significantly as more PSAPs 

become text-capable, the number of 911 

texts sent by the public is far smaller 

than the number of wireless 911 voice 

calls.33 The Commission’s text-to-911 

rules are technology neutral and apply 

to both SMS and RTT. 

18. SMS is the predominant mobile 

wireless messaging technology in use 

for 911 texts today. SMS is not an IPnative format, though IP-enabled 

networks can deliver SMS traffic. All 

three nationwide CMRS providers 

report that they are using location-based 

routing for at least some SMS texts to 

911, but this implementation appears to 

be distinct from and less extensive than 

the implementation of location-based 

routing for 911 voice calls. According to 

Verizon, ‘‘SMS still uses call path, 

routing and device processing methods 

that are distinct from VoLTE and RTT 

calls, with architecture configurations 

that still resembles second- and thirdgeneration networks in some respects.’’ 

AT&T reports that it provides devicebased hybrid location for ‘‘the majority 

of text messages’’ but does not provide 

specifics.34 T-Mobile reports that it is 

using location-based routing for at least 

some text-to-911 messages.35 Verizon 

indicates that it ‘‘has worked with its 

wireless 911 vendor Comtech to 

incorporate LBR in Comtech’s 

centralized text control center (TCC) in 

a manner that supports LBR for 911 text 

messages nationwide.’’ 36 Moreover, 

while the nationwide providers appear 

to be capable of using location-based 

routing for some SMS texts, NENA and 

other commenters indicate that 

standards have not been developed for 

location-based routing of SMS and that 

further work on standards is needed. 

19. RTT, unlike SMS, is a native IP 

technology, in which each text character 

appears on the receiving device at 

roughly the same time it is typed on the 

sending device, allowing for a 

conversational flow of communication. 

RTT also allows text characters to be 

sent simultaneously with voice, which 

allows the PSAP to both see the typed 

message and hear background noises 

and potentially the voice of the caller. 

The Commission’s rules require that 

CMRS providers choosing to implement 

RTT to and from any PSAP served by 

their network in lieu of text telephone 

(TTY) technology must do so in a 

manner that fully complies with all 

applicable 911 rules.37 The Commission 

also requires CMRS providers who 

choose to support RTT to make RTT 

backward-compatible with TTY devices. 

This enables PSAPs without end-to-end 

RTT capability to use their existing TTY 


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38RTT Order, 31 FCC Rcd at 13590, para. 39. 

Currently, RTT communications to 911 that are 

received at many PSAPs are converted to TTY. 

Letter from AnnMarie Killian, Chief Executive 

Officer, TDIforAccess, Inc., and Mark Seeger, Policy 

Coordinator, TDIforAccess, Inc., to Marlene H. 

Dortch, Secretary, FCC, PS Docket No. 18–64, at 2 

(filed Aug. 31, 2023). 

39 Verizon NPRM Comments at 5 (‘‘Verizon’s 

planned LBR implementation for VoLTE will 

support real-time-text (RTT) 911 calls.’’); see also 

ATIS NPRM Comments at 3 (urging the 

Commission ‘‘to clarify that only providers of such 

next generation text solutions [as defined in ATIS 

and NENA standards] are required to use LBR’’). 

40 In the Commission’s 2023 annual 911 fee 

report, respondents reported receiving a combined 

total of 157,999,298 wireless 911 voice calls in 

calendar year 2022 out of a total call volume of 

217,654,456 from wireless wireline, VoIP, and other 

providers. Fifteenth Annual 911 Fee Report at 13– 

16, Table 3. 

41AT&T NPRM Comments at 2; Texas 9–1–1 

Entities Public Notice Comments at 2–4 (rec. July 

11, 2022) (Texas 9–1–1 Entities PN Comments) 

(showing that average percentage of 911 call 

transfers for two out of three PSAPs in initial beta 

sites decreased by roughly 4–5% after T-Mobile 

implemented location-based routing; the remaining 

PSAP showed a slight increase in transfers of less 

than 1%); T-Mobile, T-Mobile First to Roll Out 

Cutting-Edge 911 Capabilities (Dec. 17, 2020), 

https://www.tmobile.com/news/network/tmobilenext-generation-911-location-based-routing 

(announcing that some areas where T-Mobile 

implemented location-based routing have 

experienced up to 40% fewer call transfers). 

42BRETSA NPRM Comments at 9 (‘‘By 

eliminating delay in delivery of a 9–1–1 call to the 

correct PSAP, LBR can improve outcomes.’’); 

BRETSA NPRM Reply at 4 (‘‘LBR reduces delay in 

processing and dispatching 9–1–1 calls even where 

9–1–1 [m]isroutes do not occur.’’); Industry Council 

for Emergency Response Technologies, Inc. (iCERT) 

NPRM Comments at 2 (‘‘The improved location and 

routing methodology made available with LBR will 

reduce the potential for 911 voice calls and texts to 

be directed to Public Safety Answering Points 

(PSAPs) that are not the ones best able to provide 

timely and effective response. As a result, the use 

of LBR technologies should eliminate the delays 

associated with 911 call transfers, improve 

emergency response times, and save lives.’’); 

Intrado NPRM Comments at 2 (‘‘Requiring LBR for 

all CMRS and text providers will ensure the 

availability of this life saving location technology 

for all 911 callers while increasing the efficiency of 

Public Safety Answering Points (PSAPs) by 

eliminating the time and effort to execute call 

transfers.’’); Defense Information Systems Agency 

(DISA) NPRM Comments at 2 (‘‘The vast majority 

of 911 calls from wireless devices destined for DoD 

PSAPs are currently being misrouted. DoD bases 

would immediately benefit from the reduction in 

call delivery time has a direct and immediate 

impact on emergency incident response.’’); APCO 

NPRM Comments at 1 (noting that location-based 

routing has saved valuable time for PSAPs and 

callers). In addition, AT&T notes that Kurt Mills, 

the Executive Director of Snohomish County 

(Washington) 911, has described location-based 

routing as a ‘‘game changer’’ that caused the County 

to experience a ‘‘significant decrease in 9–1–1 

transfers.’’ AT&T NPRM Comments at 1–2. 

terminals to handle RTT 911 

communications.38

20. While SMS is used more 

frequently than RTT for messaging to 

911, CMRS providers are beginning to 

partner with some PSAPs to implement 

end-to-end RTT capabilities. T-Mobile 

reports that it is currently operating 

NG911 RTT technology at a PSAP in 

Hood County, Texas. Verizon indicates 

that it now supports RTT for 911 in 

Livingston Parish, Louisiana, and Logan 

County, West Virginia. The record does 

not indicate the degree to which CMRS 

providers have implemented locationbased routing for RTT communications 

to 911, but the providers and other 

industry commenters state that locationbased routing for RTT communications 

to 911 is feasible.39

A. Location-Based Routing 

1. Wireless 911 Voice Calls 

21. We adopt requirements for 

nationwide and non-nationwide CMRS 

providers to implement location-based 

routing as proposed in the notice of 

proposed rulemaking for voice calls, 

with certain modifications. Specifically, 

we require all CMRS providers to (1) 

deploy technology that supports 

location-based routing on their IP-based 

networks (i.e., 4G LTE, 5G, and 

subsequent generations of IP-based 

networks), and (2) use location-based 

routing to route all wireless 911 voice 

calls originating on their IP-based 

networks when location information 

meets certain requirements for accuracy 

and timeliness. We note that nothing in 

this decision, including the definition of 

‘‘location-based routing’’ and other rules 

we adopt, authorizes the use of any nonU.S. satellite system in conjunction with 

the 911 system. CMRS providers seeking 

to employ foreign satellite navigation 

systems for 911 should follow the 

existing approval process. 

22. We require nationwide CMRS 

providers to comply with these locationbased routing requirements for voice 

calls within six months after the 

effective date of the final rules. We 

require non-nationwide CMRS 

providers to comply with these locationbased routing requirements for voice 

calls within 24 months after the 

effective date of the final rules in 

recognition of resource constraints faced 

by these providers. As discussed below, 

we adopt these requirements in light of 

record support that location-based 

routing for wireless 911 voice calls 

promotes public safety, is 

technologically feasible at reasonable 

cost for both nationwide and nonnationwide CMRS providers, and has 

been deployed by the three nationwide 

CMRS providers. We find that these 

requirements are necessary to extend 

the demonstrated, life-saving benefits of 

location-based routing to all wireless 

911 callers nationwide. 

a. Nationwide and Network-Wide 

Implementation 

23. We require all CMRS providers to 

deploy location-based routing 

technologies for voice calls across their 

IP-based networks. In the notice of 

proposed rulemaking, the Commission 

sought comment on whether CMRS 

providers should be required to use 

location-based routing to deliver 911 

calls to all PSAPs served by their 

networks, or whether the requirement 

should be triggered by PSAP request or 

limited to certain categories of PSAPs. 

We find that requiring CMRS providers 

to implement this technology across 

their IP network areas is necessary to 

ensure that wireless 911 callers receive 

the demonstrated benefits of improved 

routing, regardless of the caller’s 

geographic location or CMRS provider. 

24. We find that nationwide 

implementation of location-based 

routing will reduce 911 call transfers 

and improve wireless 911 service. As 

wireless 911 voice calls account for the 

vast majority of communications to 911, 

we consider it to be particularly 

important that these calls are routed to 

the appropriate PSAP.40 CMRS 

providers’ voluntary deployments of 

location-based routing have resulted in 

important and evident improvements to 

911 wireless voice call routing. The 

record indicates that ongoing 

deployments of location-based routing 

have significantly reduced the 

occurrence of transferred wireless 911 

voice calls.41 AT&T estimates that, as a 

result of its nationwide implementation, 

10% of all wireless 911 voice calls on 

its network received a more optimal 

route and therefore did not need to be 

transferred. The National Association of 

State 911 Administrators (NASNA) 

states that uniform implementation of 

location-based routing has the potential 

to route 911 calls to the right PSAP 

faster than traditional cell sector-based 

routing in many cases and, in an 

emergency, ‘‘seconds can mean the 

difference between life and death.’’ 

Public safety commenters emphasize, 

and we agree, that increasing the 

implementation of location-based 

routing will reduce delays and save 

lives.42 We find that it is in the public 

interest that the benefits of locationbased routing should extend to all 

wireless 911 callers, regardless of the 

CMRS provider or jurisdiction from 

which the call is made. 

25. Further, the public safety 

community strongly supports requiring 

CMRS providers to deploy locationbased routing on a nationwide basis. 

Several public safety organizations urge 

the Commission to require CMRS 

providers to implement location-based 


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43See, e.g., APCO NPRM Comments at 2 (stating 

that ‘‘location-based routing should be required of 

wireless carriers nationwide’’); DISA NPRM 

Comments at 2 (‘‘CMRS providers should use LBR 

to deliver 911 calls to all PSAPs served by their 

networks.’’ (emphasis in original)); Adams County 

et al. NPRM Comments at 2 (‘‘The Commission 

should require location-based routing on a 

nationwide basis.’’); Loudoun County NPRM 

Comments at 3 (‘‘Loudoun strongly supports the 

proposed rules requiring wireless carriers and 

covered text providers to implement all available 

technology options for location-based routing of 911 

calls and texts nationwide using the device-based 

location.’’); BRETSA NPRM Comments at 10 

(‘‘There is no question but that the Commission 

should require all CMRS providers to implement 

LBR for wireless voice calls and text messages as 

soon as possible.’’); Intrado NPRM Comments at 1 

(‘‘Intrado strongly supports the Commission’s 

proposed requirement for nationwide 

implementation of location-based routing (LBR) of 

wireless 911 calls and texts.’’). 

44Adams County et al. NPRM Comments at 2 

(stating that the commenting entities ‘‘have not 

experienced increased costs, adverse impacts, or 

significant issues with the implementation of 

location-based routing’’); Colorado Council of 

Authorities (CCOA) NPRM Reply at 3 (stating that 

‘‘deployments [of LBR for at least six Colorado 911 

authorities] were successful and without significant 

issue or additional expense’’). 

45We note that AT&T indicated in July of last 

year that it had ‘‘very few exceptions’’ to its 

nationwide rollout, and indicated that ‘‘a few 

PSAPs are using unique applications of Emergency 

Services Numbers to implement internal routing 

solutions. . . and that [the company was] working 

with these PSAPs to ensure [its] location-based 

routing solution meets their unique needs.’’ AT&T 

PN Comments at 4, n.3. T-Mobile also notes that it 

is aware of ‘‘at least one instance’’ in which ‘‘an 

emergency calling authority requested that another 

911 vendor indefinitely suspend using LBR for 911 

calls to its PSAPs because the vendor’s LBR 

implementation resulted in a greater number of 911 

calls that required transfer to another PSAP.’’ TMobile NPRM Comments at 5. T-Mobile did not 

provide additional details on this occurrence, 

including when it occurred or whether or not the 

issue was resolved. 

46BRETSA NPRM Comments at 3 (internal 

quotations omitted). Joseph Lyons, Dispatch 

Supervisor for the City of Poughkeepsie 911 

Communications Center, also states that locationbased routing is a ‘‘no brainer.’’ Joseph Lyons 

NPRM Comments at 1. 

47 Intrado NPRM Comments at 3, n.6. See also 

Colorado Public Utilities Commission (COPUC) 

NPRM Comments at 5–6 (‘‘The implementation of 

location-based routing on all cell tower sectors is 

the best way to ensure that instances of misrouted 

calls are minimized to the greatest extent 

possible.’’). 

48Michigan State 911 NPRM Comments at 1 

(‘‘[H]aving some [CMRS providers] provide LBR 

while others do not, creates an expectation for 

callers that all wireless calls provide this 

information to 911 centers, and that 911 centers 

will be able to locate them when they are 

experiencing an emergency.’’). 

49See, e.g., T-Mobile NPRM Comments at 3 (‘‘TMobile cautions the Commission from adopting 

rules that require wireless carriers to do nothing 

more than turn on location-based routing regardless 

of PSAP preference.’’); Verizon NPRM Comments at 

2 (‘‘[I]nstead of a blanket flash-cut nationwide 

implementation deadline, implementation should 

be based on PSAP requests. . . .’’); CTIA NPRM 

Comments at 4 (‘‘[A]ny obligation for a provider to 

commence use of LBR to route wireless 9–1–1 voice 

calls to a PSAP should only be triggered by a ‘valid 

request’ from a state or local 9–1–1 authority.’’). 

One public safety commenter, the Colorado Council 

of Authorities (CCOA), also ‘‘gives deference to the 

comments of T-Mobile, Verizon, and CTIA that 

deployment of LBR for wireless 911 voice calls 

should be initiated by a valid request from a PSAP 

or governing 911 authority.’’ CCOA NPRM Reply at 

1 (footnote omitted). 

50 Verizon NPRM Comments at 2; T-Mobile 

NPRM Comments at 3; iCert NPRM Comments at 2; 

RWA NPRM Comments at 4; Southern Linc NPRM 

Reply at 4; see also AT&T NPRM Comments at 3 

(arguing for either a per-PSAP approach or ‘‘a 

process under which a PSAP could signal that it 

requires more time to achieve readiness, and that 

PSAP would be carved out from the six-month 

requirement.’’). 

51CTIA NPRM Comments at 4 (stating that ‘‘[t]o 

make a valid request, a PSAP should be technically 

ready to receive 9–1–1 calls routed using LBR’’); 

CCA Notice of Proposed Rulemaking Reply at 6 

(rec. Mar. 20, 2023) (CCA NPRM Reply); RWA 

NPRM Comments at 3. 

52T-Mobile NPRM Comments at 7 (stating that a 

valid request must be conditioned on ‘‘the 

provision of accurate shapefiles—and the 

maintenance and update of those shapefiles’’). 

53As Intrado notes, CMRS providers must 

implement a geospatial routing-capable Gateway 

Mobile Location Center (GMLC) in order to enable 

their networks to support location-based routing. 

Intrado NPRM Comments at 3. 

routing. Other public safety commenters 

and Intrado also support a nationwide 

location-based routing requirement.43

The record indicates that the 

nationwide CMRS providers have 

implemented location-based routing 

without increased costs or problems for 

public safety.44 In particular, no 

commenter indicates that AT&T’s 

nationwide implementation of locationbased routing, completed to ‘‘virtually 

all’’ PSAPs in June 2022, has caused 

additional cost or other problems for 

public safety.45 Given the success of 

nationwide CMRS providers in 

voluntarily implementing locationbased routing on their IP-based 

networks, and in particular the success 

of AT&T’s nationwide implementation, 

we agree with Boulder Regional 

Emergency Telephone Service Authority 

(BRETSA), which states that requiring 

wireless service providers to implement 

location-based routing at the earliest 

possible moment is ‘‘a no-brainer.’’ 46

26. We also find that requiring 

location-based routing to all PSAPs 

nationwide supports the Commission’s 

goal to promote parity of wireless 911 

service across jurisdictions. NASNA 

states, and we agree, that ‘‘[a]ttempting 

to create areas of exclusive enhanced 

location accuracy fosters deployment of 

disparate levels of service; all those who 

call or text 911 should benefit from 

LBR.’’ NENA points out, and we agree, 

that ‘‘[i]t would be inequitable to restrict 

the life-saving benefits of location-based 

routing only to residents of and visitors 

to the United States with the good 

fortune of having an emergency in a 

convenient location.’’ Commenters also 

urge the Commission not to limit 

deployment of this technology to 

jurisdictions subject to frequent 

misroutes or to jurisdictions that have 

deployed NG911 capabilities. Intrado 

comments that even in low misroute 

areas, the implementation of locationbased routing will result in a significant 

reduction in misroutes compared to 

relying exclusively on tower-based 

routing.47 Public safety commenters also 

note that implementation of locationbased routing on a nationwide basis will 

provide technological consistency for 

PSAPs, which will help them provide 

better service, and that technological 

consistency between CMRS providers is 

important for managing the expectations 

of 911 callers.48

27. Wireless industry commenters 

oppose a mandatory nationwide 

approach,49 arguing instead that CMRS 

providers should implement locationbased routing voluntarily or only in 

response to individual PSAP requests.50

These commenters argue that CMRS 

providers should only be required to use 

location-based routing for 911 calls to a 

particular PSAP after receiving a valid 

request from that PSAP. In addition, 

they argue that for a PSAP request to be 

deemed valid, the PSAP should be 

required to demonstrate that it is 

‘‘technically ready’’ 51 to receive calls 

routed using location-based routing and 

to provide shapefiles of PSAP 

boundaries to CMRS providers.52 As 

explained below, we find that the 

concerns of industry commenters are 

unsupported in the record, contradict 

the stated preferences of public safety 

for a nationwide approach to 

deployment, and would unnecessarily 

delay the benefits of location-based 

routing to the public. 

28. Per-PSAP Implementation. We 

decline to adopt a per-PSAP 

deployment approach. Contrary to the 

assertion of industry commenters, the 

record does not demonstrate that 

individual PSAPs must take specific 

technical steps in order to be ready to 

receive wireless 911 calls routed using 

location-based routing. The generation 

of location-based routing information as 

contemplated in this proceeding occurs 

entirely within CMRS provider 

networks prior to call delivery to the 

PSAP,53 and therefore there are no 

specific actions that PSAPs need to take 

to be technically ready to receive 

wireless 911 calls routed by devicebased rather than tower-based location. 

As the Colorado Public Utilities 

Commission (COPUC) states, ‘‘Because 

LBR is performed before the call is even 

delivered to the 9–1–1 system service 

provider for delivery to the PSAP, there 


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54AT&T Comments at 3. In a news release 

announcing AT&T’s rollout of location-based 

routing, AT&T stated ‘‘The nationwide rollout has 

started and is available in Alaska, Colorado, Hawaii, 

Idaho, Montana, Oregon, Washington, Wyoming, 

Kansas, Illinois, Iowa, Minnesota, North Dakota, 

Missouri, Nebraska, South Dakota and Guam. 

Additional regions will be rolled out over the next 

several weeks. The nationwide rollout is scheduled 

to be completed by the end of June.’’ Press Release, 

AT&T, AT&T Launches First-Ever Nationwide 

Location-Based Routing with Intrado to Improve 

Public Safety Response for Wireless 9–1–1 Calls 

(May 10, 2022), at https://about.att.com/story/2022/ 

nationwide-location-based-routing.html. 

55T-Mobile NPRM Comments at 5 (emphasis 

omitted). 

56See Metropolitan Emergency Services Board, 

Metropolitan Emergency Services Board 9–1–1 

Technical Operations Committee July 15, 2021 Draft 

Meeting Minutes at 7, https://mn-mesb.org/wpcontent/uploads/July-TOC-Meeting-Packet070921.pdf (indicating that at the time of 

deployment in select counties in Minnesota, no 

other carriers had deployed or announced future 

deployment of location-based routing); 

Metropolitan Emergency Services Board, 

Metropolitan Emergency Services Board 9–1–1 

Technical Operations Committee Agenda at 25 (Jan. 

21, 2021), https://mn-mesb.org/wp-content/ 

uploads/January-Meeting-911-TOC-Packet012121.pdf (including a presentation from T-Mobile 

to Greater Harris County, Texas, indicating that 

‘‘[t]oday, T-Mobile is the only wireless carrier 

positioned to route 911 calls based on caller 

location, rather that [sic] cell sector’’). 

57T-Mobile NPRM Comments at 5; see also iCERT 

NPRM Comments at 2 (arguing for a per-PSAP 

approach as location-based routing ‘‘may impact a 

PSAP’s operations’’). 

58T-Mobile NPRM Comments at 4; CCOA NPRM 

Reply Comments at 1–2; see also 47 CFR 9.10(d)(1), 

(f), (g), (m). 

59T-Mobile NPRM Comments at 4; CTIA NPRM 

Comments at 4; see also 47 CFR 9.10(q)(10)(ii) and 

(iii). 

60To receive texts, PSAPs must either upgrade 

their equipment to receive text messages or 

implement text-to-911 capabilities on existing 

equipment. T911 Second Report and Order, 29 FCC 

Rcd at 9861, para. 32, 79 FR 55367 (September 16, 

2014). To receive Phase I location information, 

PSAPs must use switches, protocols, and signaling 

systems that will allow them to obtain the calling 

party’s number from the transmission of ANI. 

Revision of the Commission’s Rules to Ensure 

Compatibility with Enhanced 911 Emergency 

Calling Systems, CC Docket No. 94–102, RM–8143, 

Report and Order, 11 FCC Rcd 18676, 18709, para. 

63 n.119 (1996), 61 FR 40348 (August 2, 1996). To 

receive Phase II location information, PSAPs must 

‘‘install equipment to determine the geographic 

coordinates of the caller, transfer that information 

through the telephone networks, and have a 

mapping system in place at the PSAP that can 

display the latitude and longitude coordinates of 

the caller as a map location for dispatching 

assistance.’’ General Accounting Office, Uneven 

Implementation of Wireless Enhanced 911 Raises 

Prospect of Piecemeal Availability for Years to 

Come, GAO–04–55, at 9 (Nov. 2003), https://

www.gao.gov/assets/gao-04-55.pdf. 

is no additional preparation that must 

be made by the PSAP in order for 

carrier-provided LBR to be of benefit.’’ 

29. AT&T’s completed rollout of 

location-based routing on its nationwide 

network provides additional evidence 

that location-based routing can be 

successfully deployed without requiring 

PSAPs to demonstrate technical 

readiness. AT&T deployed locationbased routing in 2022 on a region-byregion basis and completed its 

nationwide rollout in less than six 

months.54 Moreover, although AT&T 

supports the Commission adopting a 

per-PSAP approach in which each PSAP 

would have to request location-based 

routing, it is notable that AT&T did not 

use this approach in its own rollout. 

Instead, AT&T deployed location-based 

routing to ‘‘virtually all PSAPs’’ in the 

U.S. without soliciting PSAP-by-PSAP 

requests or requiring each PSAP to 

demonstrate technical readiness. Thus, 

it does not appear that these are 

necessary prerequisite steps before 

CMRS providers implement locationbased routing nationwide on their 

networks. 

30. We also do not agree with 

commenters’ assertions that PSAPs are 

not ready from an operational 

perspective to manage changes in call 

distribution or volume resulting from 

the implementation of location-based 

routing on a nationwide basis. T-Mobile 

asserts that ‘‘[m]any emergency 

authorities want to understand the 

impact LBR will have on operations, 

call volume, and workflows before 

deploying it; they often also want the 

ability to implement reporting and 

tracking of call transfers prior to 

enabling LBR in order to understand 

and see the effects of the new 911 

routing.’’ 55 T-Mobile cites its initial 

implementation of location-basedrouting in Minnesota and Texas,56

where T-Mobile states that 911 

authorities required First Office 

Applications (FOAs) before expanding 

deployment to more PSAPs. However, 

T-Mobile’s initial deployments in those 

areas occurred at a time when no other 

carrier had deployed location-based 

routing for 911 anywhere in the U.S., 

which could reasonably lead the first 

PSAPs receiving location-based routed 

calls to take a cautious approach. Since 

then, AT&T has implemented locationbased routing nationwide to thousands 

of PSAPs with no reported adverse 

operational impacts. To the contrary, 

the record indicates that PSAPs have 

reaped operational benefits from 

implementation of location-based 

routing in the form of reduced misroutes 

and call transfers. 

31. CMRS providers’ assertions about 

potential adverse operational impacts to 

PSAPs are also contradicted by virtually 

all statements of public safety 

commenters on the record. Despite 

industry commenters’ preference,57 the 

vast majority of public safety 

commenters support a rapid nationwide 

rollout of location-based routing and 

specifically oppose the per-PSAP 

approach advocated by CMRS 

providers. Only one public safety 

commenter, the Colorado Council of 

Authorities, Inc. (CCOA), supports the 

per-PSAP approach in order to ensure 

‘‘collaboration’’ between PSAPs and 

service providers. We agree that such 

collaboration is important to the 

successful implementation of locationbased routing, and we encourage PSAPs 

and 911 authorities to collaborate 

during the implementation period 

established. However, this does not 

require establishing a process in which 

every PSAP must affirmatively opt in to 

location-based routing. In fact, such a 

process would be far more cumbersome 

than a uniform nationwide 

implementation timetable and could 

lead to fragmented and inconsistent 

deployment. We agree with APCO that 

given the immediate feasibility of 

nationwide implementation, substantial 

voluntary deployment that has already 

occurred, and the clear public safety 

benefits of location-based routing, 

deployment and use of location-based 

routing should not be optional or 

conditional. 

32. We are also not persuaded by 

commenters who compare 

implementation of location-based 

routing to past implementation of the 

Commission’s E911 Phase I and Phase II 

location requirements 58 or text-to-911,59

which were predicated on individual 

PSAPs achieving the technical 

capability to receive E911 location data 

and 911 texts, respectively.60 For 

location-based routing, there is no 

similar reason to predicate CMRS 

provider compliance on PSAP technical 

capability, because AT&T’s rollout 

demonstrates that PSAPs do not need to 

have any specific technical capabilities 

in place to receive calls routed using 

location-based routing. Accordingly, we 

agree with COPUC that ‘‘[t]here is no 

compelling reason to require PSAPs to 

opt in to this service or to predicate the 

use of location-based routing 

methodology on any sort of ‘readiness’ 

of the PSAP.’’ Implementing locationbased routing on a per-PSAP basis could 

lead to uneven and inconsistent 

implementation of routing approaches 

between jurisdictions and result in a 

risk of wireless 911 misroutes for 

jurisdictions that do not request 

location-based routing service. We find 

that this would be contrary to the public 

interest and the Commission’s interest 

in facilitating improved routing of 

wireless 911 voice calls. 

33. Voluntary Implementation. We 

also decline to permit CMRS providers 

to deploy location-based routing on a 


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61CTIA NPRM Reply at 3 (urging the Commission 

to provide flexibility for wireless providers to 

implement location-based routing in the manner 

that meets their ‘‘unique network and handset 

configurations’’ and is coordinated with public 

safety); see also CCA NPRM Reply at 1–2. 

62ATIS–0700042 at 6. CCA argues that limiting 

location-based routing to IP-based wireless 

networks provides ‘‘an important increment of 

regulatory relief’’ but notes that this relief is limited 

because many non-nationwide carriers have already 

retired non IP-based technology. CCA NPRM 

Comments at 12. CCA also asserts that limiting 

location-based routing to IP networks does not 

reduce costs burdens on the wireless sector. Id. at 

12–13. Nonetheless, we find that this provision will 

ease burdens for CMRS providers that have not yet 

transitioned to IP-based networks. 

63See Verizon July 13, 2023 Ex Parte at 1 (‘‘If 

Verizon has a [s]hapefile of the PSAP’s boundaries 

due to earlier E911 deployments or upgrades, the 

PSAP may be able to simply confirm that the earlier 

document remains accurate.’’); GCI Aug. 7, 2023 Ex 

Parte at 5 (‘‘GCI’s network serves geographic areas 

where the boundaries between PSAP service areas 

are sparsely populated or unpopulated, in general. 

Therefore, the existing shapefiles could likely be 

used to route calls using more precise on-device 

location as well.’’). 

64See NASNA NPRM Comments at 4 (‘‘Legacy 

and enhanced 911 relies on tabular location 

databases that are updated by the originating 

service providers (OSPs), and maintained by the 

911 service provider to act as the authoritative 

source of location information used to validate the 

location of the 911 caller.’’). 

purely voluntary basis. Wireless entities 

supporting voluntary implementation 

argue that flexibility in implementation 

is needed to account for differences in 

providers’ networks and devices and to 

allow technologies to continue to 

evolve.61 However, public safety 

commenters note that permitting CMRS 

providers to deploy location-based 

routing on a purely voluntary basis 

would require additional and 

unnecessary coordination and would 

only delay the implementation of 

location-based routing as a general 

matter. The record confirms the 

Commission’s reasoning in the notice of 

proposed rulemaking that relying on 

voluntary implementation would 

‘‘result in inconsistent routing of calls to 

PSAPs and a higher risk of 911 

misroutes for subscribers on CMRS 

networks that did not support locationbased routing.’’ Thus, we find that 

allowing CMRS providers to implement 

location-based routing on a voluntary 

basis would undermine our goal of 

ensuring that this important capability 

benefits all wireless 911 callers 

nationwide. 

b. Technical Considerations 

34. Technological Feasibility. We find 

that implementing location-based 

routing for wireless 911 voice calls is 

technologically feasible for nationwide 

and non-nationwide CMRS providers. 

The three nationwide CMRS providers 

have implemented location-based 

routing for wireless 911 voice calls 

across or for some part of their 

networks. CCA, an industry association 

with membership including nonnationwide CMRS providers, states that 

‘‘wireless carriers can eventually deploy 

location-based routing to any PSAP’’ if 

provided with adequate time and 

financial support. iCERT agrees that 

location-based routing is technologically 

feasible. NGA 911 also offers support for 

this conclusion, stating that both 

Google’s Emergency Location Service 

(ELS) and Apple’s Hybridized 

Emergency Location (HELO) provide a 

device location estimate, and these 

mobile operating systems comprise 

99.62% of the handset market. NENA 

states that AT&T’s nationwide 

deployment of location-based routing 

demonstrates that ‘‘transitional locationbased routing mechanisms are 

technically feasible and improve 9–1–1 

outcomes, and are in use today.’’ No 

commenter argues that implementing 

location-based routing on CMRS 

provider networks is technologically 

infeasible. 

35. Calls originating on IP-based 

networks. In light of the technical 

obstacles and ongoing retirement of 

legacy networks, we apply our locationbased routing requirements to IP-based 

networks but we decline to require 

location-based routing for 911 calls 

originating on circuit-switched, timedivision multiplex (TDM) networks. 

This is consistent with the 

Commission’s proposal in the notice of 

proposed rulemaking and is supported 

by commenters. For example, the Rural 

Wireless Association (RWA) agrees that 

requiring location-based routing for 911 

calls originating on TDM networks 

would be unduly burdensome. CCA 

asserts that ‘‘TDM networks can lack the 

speed and capacity necessary to 

transmit and evaluate confidence and 

uncertainty information and query the 

location server for PSAP routing 

instructions prior to the time for a call 

to commence.’’ ATIS assumes for 

purposes of ATIS–0700042 that 

location-based routing is only supported 

on originating networks supporting 

Long Term Evolution (LTE) and 

beyond.62

36. PSAP Boundary Maps. Some 

commenters contend that location-based 

routing requirements should be 

conditioned on 911 authorities 

providing updated maps or shapefiles of 

PSAP boundaries to CMRS providers. 

We conclude that such a condition is 

unnecessary. We recognize that 

accurately mapping PSAP jurisdictional 

boundaries is important to the accurate 

routing of 911 calls. However, the 

record demonstrates that CMRS 

providers and the third-party vendors 

they use to route 911 calls already have 

maps and shapefile records of PSAP 

boundaries generated to support earlier 

E911 deployments and upgrades,63 and 

that ‘‘numerous companies’’ maintain 

PSAP boundary shapefile information to 

support CMRS 911 call routing. CMRS 

providers have long used this 

information to support legacy towerbased routing of 911 voice calls.64

Moreover, the Commission has never 

conditioned the 911 routing obligations 

of CMRS providers on PSAPs or 911 

authorities providing mapping data. As 

NASNA explains, legacy and E911 

routing ‘‘relies on tabular location 

databases that are updated by the 

originating service provider,’’ and 911 

authorities may support the 

maintenance and quality assurance of 

these databases, but ‘‘there are no rules 

addressing how frequently this data 

must be updated, nor is there 

transparency when data updates are 

operationalized.’’ 

37. The record indicates that CMRS 

providers and their vendors can use 

existing PSAP boundary information to 

support location-based routing to the 

same extent that such information has 

supported tower-based routing. The 

purpose of this information is to 

associate a specified location—whether 

it is the caller’s location or the tower 

location—with the jurisdiction served 

by a particular PSAP, and CMRS 

providers are already using this 

information to support their 

implementation of location-based 

routing. If PSAP boundary maps are not 

updated to reflect current jurisdictional 

boundaries, it is possible that some calls 

originated near those boundaries could 

be misrouted even when location-based 

routing is used. However, the overall 

frequency of misroutes is still likely to 

be lower than with tower-based location 

because tower-based location routes all 

calls in a cell sector to the same PSAP 

regardless of the jurisdiction where the 

caller is located. For example, GCI states 

that ‘‘existing shapefiles could likely be 

used to route calls using more precise 

on-device location’’ information on its 

network, although the importance of 

updated maps may be affected in some 

locations by factors such as population 

density near the PSAP boundary area, 

the number of PSAPs served, and the 

density of cell sites. BRETSA comments 

that the record does not indicate 

whether the provider of the PSAP 

boundary maps AT&T is relying on 

‘‘could and would also provide them to 

non-national providers and on what 

terms.’’ As noted above, we conclude 


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65NASNA NPRM Comments at 11 (‘‘By 

definition, LBR will introduce delay into the 

delivery of the 911 call or text to NG911 that is no 

longer needed with a fully functional NG911 system 

that is using geospatial routing.’’); Texas 9–1–1 

Entities NPRM Comments at 4 (noting that the 

NG911 transition in some areas ‘‘may potentially 

make it unnecessary for some CMRS providers to 

make LBR modifications to their existing legacy 9– 

1–1 solutions, at least in those areas’’). 

66NASNA NPRM Comments at 6 (‘‘For localities 

that have deployed any form of NG911 this 

unrestricted access to 911 call routing data is 

mission critical. . . .’’). 

67See Verizon NPRM Comments at 3 (stating that 

some jurisdictions ‘‘have implemented their own 

form of LBR and prefer that originating service 

providers not also perform LBR on a call’’). 

68BRETSA NPRM Reply Comments at 5; see also 

Intrado PN Comments at 10 n.14 (‘‘Implementing 

LBR on the carrier side has the added benefit of 

avoiding any potential adverse consequences to the 

present transitional NG911 environment and 

eventual NG911 end state. In fact, LBR (and the 

enhanced location information behind it) will work 

hand-in-hand with the PSAPs ongoing NG911 

adoption of IP-based, geospatial ESInets.’’). 

69See Intrado NPRM Comments at 5 (‘‘[T]he 

carrier GMLC now has sufficient information and 

time with 4G/5G to determine, transmit and 

evaluate confidence and uncertainty of devicebased location information and to query the 

location server for PSAP routing instructions before 

the time to route.’’). 

70AT&T completed the rollout of location-based 

routing on its network in June 2022 and uses 

location-based routing to deliver wireless 911 voice 

calls and texts to nearly all PSAPs nationwide. 

AT&T PN Comments at 4; AT&T NPRM Comments 

at 1. T-Mobile launched location-based routing on 

its network in the states of Texas and Washington 

in 2020 and as of December 2023 has fully 

implemented location-based routing for 1,591 

PSAPs with an additional 596 PSAPs in progress. 

T-Mobile NPRM Comments at 3–5; T-Mobile PN 

Reply at 2 n.6. In December 2023, Verizon reported 

that it had initiated location-based routing for 414 

PSAPs with an additional 277 PSAPs in progress. 

Verizon Dec. 7, 2023 Ex Parte at 1. 

that it is not necessary for AT&T’s 

provider of PSAP boundary maps to 

provide them to other CMRS providers, 

who should be able to use their existing 

sources of boundary maps. 

38. While we do not require PSAPs to 

provide updated shapefiles as a 

prerequisite to location-based routing, 

we recognize that location-based routing 

is most effective when service providers 

use up-to-date shapefiles that precisely 

and accurately identify jurisdictional 

boundaries for routing purposes. In 

addition, we recognize that 911 

authorities and PSAPs are the most 

authoritative source for current 

jurisdictional boundary information. 

Therefore, we encourage CMRS 

providers and their third-party vendors 

to work with 911 authorities and PSAPs 

to ensure that location-based routing 

decisions on CMRS provider networks 

are based on shapefiles that accurately 

reflect current boundaries. NENA 

suggests establishment of an 

‘‘authoritative database for PSAP 

boundary information’’ and states that 

with sufficient funding and appropriate 

governance, this tool could be expanded 

to serve as the industry’s authoritative 

reference for location-based routing 

purposes. We encourage 911 authorities, 

relevant industry groups, and CMRS 

providers to consider further whether 

such a database is needed, what steps to 

take, and what parties should take them. 

39. NG911 Geospatial Routing. 

NASNA and the Texas 9–1–1 Entities 

suggest that as jurisdictions transition to 

NG911, location-based routing by CMRS 

providers may not be necessary and 

could cause delay in call routing by 

NG911-capable jurisdictions that will 

use ESInets and geospatial routing to 

route calls to individual PSAPs.65 While 

these parties are correct that NG911 will 

introduce new geospatial routing 

mechanisms, this does not obviate the 

need for the location-based routing 

requirements we adopt, nor will these 

requirements impede NG911 call 

routing. 

40. First, while many states have 

already made significant commitments 

to implementing NG911, the NG911 

transition remains ongoing, and there 

are no fully enabled NG911 systems yet 

operating. As COPUC notes, ‘‘most 911 

call delivery networks do not have the 

ability to provide geospatial routing at 

this time and it is unknown when such 

technology will be universally 

deployed. Requiring CMRS providers to 

deploy LBR in the meantime is essential 

. . . .’’ 66 We agree. 

41. Second, the provision of locationbased routing information by CMRS 

providers will remain essential in the 

NG911 environment because NG911 

systems will need this information to 

perform the additional geospatial 

routing functions necessary to direct 

911 calls to the correct PSAP behind the 

ESInet.67 APCO notes that ‘‘[w]ireless 

service providers perform routing 

functions before passing a 9–1–1 call or 

text to a 9–1–1 network—regardless of 

whether the 9–1–1 network is legacy or 

IP-based—and even if such networks are 

able to perform an additional routing 

function, carriers should remain 

responsible for first engaging in 

location-based routing.’’ BRETSA 

further notes that location-based routing 

‘‘is not inconsistent with the eventual 

transition to full i3 NG9–1–1.’’ 68

Finally, we do not agree that locationbased routing implemented on CMRS 

networks consistent with the proposed 

rules will introduce delay into NG911 

call routing. The location-based routing 

requirements we adopt expressly apply 

only when location information meeting 

the accuracy threshold is available at 

time of routing. Thus, these 

requirements will not delay delivery of 

911 calls in either the legacy E911 

environment or the NG911 

environment.69

c. Compliance Timelines 

42. Overview. We require nationwide 

CMRS providers to comply with the 

location-based routing requirements 

within six months after the effective 

date of the final rules, as proposed in 

the notice of proposed rulemaking. We 

require non-nationwide CMRS 

providers to comply with the locationbased routing requirements within 24 

months after the effective date of the 

final rules, a time frame which is six 

months longer than the eighteen months 

proposed in the notice of proposed 

rulemaking. We also permit a PSAP and 

a CMRS or covered text provider to set, 

by mutual consent, alternative deadlines 

to implement location-based routing in 

the PSAP’s jurisdiction that are different 

from those otherwise established by the 

rules. 

43. Nationwide CMRS Providers. We 

require nationwide CMRS providers to 

comply with the location-based routing 

requirements within six months after 

the effective date of the final rules, as 

proposed in the notice of proposed 

rulemaking. NENA, COPUC, NASNA, 

DISA, and iCERT support the proposed 

six-month timeline for nationwide 

CMRS providers, and no commenter 

indicates that it would be infeasible or 

burdensome for nationwide CMRS 

providers to complete the 

implementation of location-based 

routing within six months. The three 

nationwide CMRS providers have 

already deployed or are actively 

working toward deploying locationbased routing capabilities on their 

networks, indicating that they have 

made substantial progress in 

implementing this technology at the 

network level.70 AT&T has already 

deployed location-based routing on a 

nationwide basis. Verizon has indicated 

that it is ‘‘turning up Location-Based 

Routing for hundreds of PSAPs 

nationwide’’ and directs ‘‘PSAPs that 

are interested in deploying Location 

Based Routing to contact Verizon 

engineers.’’ This statement indicates 

Verizon’s readiness to deploy locationbased routing and that Verizon has 

made necessary progress to implement 

the technology at the network level. TMobile was the first to deploy this 

technology on its network in 2020 and 

as of December 2023 had fully 

implemented location-based routing for 

1,591 PSAPs with an additional 596 

PSAPs in progress, which indicates that 


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71Notice of Proposed Rulemaking, 37 FCC Rcd at 

15195, para. 26. 

72NASNA NPRM Comments at 11 (agreeing with 

18-month timeline for non-nationwide CMRS 

providers); iCERT NPRM Comments at 2 

(supporting 18-month timeline for non-nationwide 

CMRS providers); COPUC NPRM Comments at 3 

(agreeing with the 18-month timeline for nonnationwide CMRS providers); see also NENA 

Comments at 3 (stating, as a general matter, that 

‘‘the Commission has proposed sufficient 

compromises to avoid undue burden on the 

wireless industry, such as a later implementation 

date for non-nationwide CMRS providers’’). 

73Adams County et al. NPRM Comments at 2 

(stating that 18-month implementation schedule for 

non-nationwide CMRS providers is ‘‘acceptable,’’ 

but noting that ‘‘[s]ooner is better’’); APCO NPRM 

Comments at 3. BRETSA comments that nonnationwide CMRS providers have not yet 

determined the actual cost and time required to 

implement location-based routing, and urges the 

Commission to require non-nationwide CMRS 

providers to implement location-based routing 

within six or twelve months (i.e., rather than 

eighteen months) and to ‘‘grant waivers or 

extensions upon showings of the actual costs of and 

impediments to deployment.’’ BRETSA NPRM 

Reply at ii; id. at 13 (‘‘Such an approach would 

allow providers a reasonable time to implement 

LBR, while avoiding unnecessary delay and impacts 

upon victims of accidents, illnesses, crimes, and 

fires.’’). BRETSA also suggests that in rural areas, 

which generally have a lower incidence of 

misroutes (e.g., because a single PSAP serves the 

entire county), regional wireless providers should 

have an ‘‘earlier date for implementation of LBR,’’ 

with deployment prioritized based on the level of 

misroutes, and ‘‘allowing a longer overall phase-in 

period.’’ BRETSA NPRM Comments at 7–8. 

74RWA NPRM Comments at 1–3. RWA discusses 

reasons smaller carriers require more time and 

financial support, including that ‘‘many RWA 

members are in the midst of efforts to ‘rip and 

replace’ unsecure Huawei and ZTE equipment in 

their networks,’’ id. at 2, which is a ‘‘top priority 

over regulatory compliance unrelated to national 

security.’’ Id. at 3. RWA requests small rural CMRS 

providers have 36 months from effective date of 

final rules to implement, ‘‘and then only if the 

PSAP is capable of handling the call routing.’’ Id. 

at 3. 

it has made progress on implementing 

the technology on a network level. 

44. The nationwide CMRS providers 

do not argue for an implementation 

timeline that is longer than six months 

from the effective date of the rules. 

Instead, T-Mobile, AT&T, Verizon, and 

CTIA support a six-month timeline for 

nationwide providers conditioned on 

each PSAP requesting location-based 

routing and demonstrating technical 

and operational readiness. As discussed 

above, we have determined that a perPSAP request mechanism would delay 

the critical benefits of a nationwide 

deployment of location-based routing 

and is not a necessary component to 

ensure PSAP operational continuity 

during the transition. Industry 

commenters’ arguments nevertheless 

indicate that nationwide providers are 

capable, from both a technical and cost 

perspective, of deploying location-based 

routing within a six month timeframe. 

Indeed, if the Commission were to adopt 

a per-PSAP request mechanism and all 

or virtually all PSAPs opted in 

immediately, the nationwide CMRS 

providers would effectively be required 

to deploy location-based routing 

nationwide within six months. Finally, 

we accord little weight to AT&T’s 

request to condition CMRS provider 

compliance timelines on PSAP requests, 

as AT&T deployed location-based 

routing on a nationwide basis and states 

that it ‘‘was able to deploy locationbased routing to virtually all PSAPs 

within a six-month timeframe,’’ with 

few exceptions. 

45. Some commenters point out that 

the nationwide CMRS providers had 

several years to plan and carry out their 

voluntary implementation of locationbased routing. However, we disagree 

that this argues in favor of allowing the 

nationwide providers more than six 

months to complete nationwide 

implementation. Location-based routing 

technology is no longer nascent, 

unknown to PSAPs, or unproven. Use of 

location-based routing has expanded 

significantly since 2020, when T-Mobile 

first deployed it, technical standards 

now exist for its implementation, all 

three nationwide carriers have deployed 

it on their networks, and public safety 

is aware of and eager for this improved 

routing technology. Given the extent of 

this progress, we believe that six months 

is more than adequate for nationwide 

CMRS providers to implement locationbased routing nationwide. We therefore 

find that six months from the effective 

date of the rules provides adequate time 

for these providers to complete the 

implementation on their networks. 

NENA, COPUC, NASNA, DISA, and 

iCERT support the proposed six-month 

timeline for nationwide CMRS 

providers, and no commenter indicates 

that it would be infeasible or 

burdensome for nationwide CMRS 

providers to complete the 

implementation of location-based 

routing within six months. 

46. APCO, Adams County et al., and 

Fenwick support a timeline shorter than 

six months for nationwide providers to 

deploy location-based routing. We 

decline to adopt a shorter mandatory 

timeline, as it is unclear whether it is 

feasible for all three nationwide CMRS 

providers to complete their deployment 

of location-based routing in fewer than 

six months. However, nationwide CMRS 

providers may deploy location-based 

routing voluntarily prior to the 

compliance deadline. 

47. Non-Nationwide CMRS Providers. 

In the notice of proposed rulemaking, 

the Commission proposed an 18-month 

timeline for non-nationwide CMRS 

providers to implement location-based 

routing.71 We received mixed comments 

on this issue. NASNA, iCERT, and 

COPUC support the proposed 18-month 

timeline for non-nationwide CMRS 

providers,72 while other public safety 

entities argue for a shorter timeline.73

On the other hand, CMRS provider 

commenters generally support a longer 

timeline for non-nationwide CMRS 

providers to implement location-based 

routing. CTIA states that ‘‘nonnationwide providers need more time to 

deploy LBR capability than the 18 

months proposed in the NPRM due to 

the significant costs and technical 

modifications necessary to implement 

LBR.’’ GCI recommends that nonnationwide CMRS providers be given a 

timeline of at least 24 months or 

potentially longer. RWA recommends 

that small rural CMRS providers be 

given 36 months to implement locationbased routing.74 CCA asserts that nonnationwide providers need at least four 

years to ‘‘select, test, modify, perfect, 

and deploy’’ location-based routing, 

stating that AT&T’s deployment took 

four years and that ‘‘[m]ost CCA 

member companies do not possess 

anywhere near the scope and scale of 

resources that AT&T enjoys.’’ Southern 

Linc agrees with CCA’s concerns that 

non-nationwide CMRS providers may 

require considerably longer than 18 

months. 

48. The Commission has previously 

recognized that non-nationwide CMRS 

providers can face obstacles that 

warrant additional time for compliance 

beyond the time afforded to nationwide 

CMRS providers during technology 

transitions. Smaller CMRS providers 

may have difficulty obtaining necessary 

commitments from device makers, 

technology vendors, and software 

service providers to implement locationbased routing within a time frame that 

would be feasible for nationwide CMRS 

providers. We therefore adopt a timeline 

of twenty-four months (two years) from 

the effective date of the rules for nonnationwide CMRS providers to deploy 

and begin using location-based routing. 

This timeline provides an additional 18 

months beyond the deadline applicable 

to nationwide CMRS providers. We 

adopt this extended timeline in 

recognition of the obstacles that nonnationwide CMRS providers may 

encounter in deploying location-based 

routing on their networks. We also 

anticipate that the additional time will 

assist non-nationwide CMRS providers 

in absorbing capital costs. It is 

consistent with past Commission 

decisions to permit non-nationwide 

CMRS providers additional time to 


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75For example, for horizontal location accuracy 

requirements, certain benchmarks for nonnationwide CMRS providers are tied to the 

deployment of specifical technical capabilities, 

which has permitted additional time for 

compliance. See 47 CFR 9.10(i)(2)(i)(B)(3), (4). For 

vertical location accuracy requirements, certain 

non-nationwide CMRS providers are permitted an 

additional year to meet relevant benchmarks. See 47 

CFR 9.10(i)(2)(ii)(F). 

76 47 CFR 1.925. 

77FCC, Secure and Trusted Communications 

Networks Reimbursement Program Second Report 

at 4 (July 10, 2023), https://docs.fcc.gov/public/ 

attachments/DOC-395005A1.pdf. See Protecting 

Against National Security Threats to the 

Communications Supply Chain Through FCC 

Programs, WC Docket No. 18–89, Second Report 

and Order, 35 FCC Rcd 14284, 14354, para. 170 

(2020), 86 FR 2904 (January 13, 2021). The 

Commission may grant recipients extensions of this 

term on an individual basis. See Secure and Trusted 

Communications Networks Act of 2019, Public Law 

116–124, section 4(d)(6)(C), 134 Stat. 158, 163 

(2020) (Secure Networks Act) (codified at 47 U.S.C. 

1603(d)(6)(C)). 

78A Reimbursement Program recipient may 

request and the Commission may grant an 

individual extension of a recipient’s removal, 

replacement, and disposal term for a period of up 

to six months after the Bureau finds, that due to no 

fault of such recipient, such recipient is unable to 

complete the permanent removal, replacement, and 

disposal by the end of the term. 47 CFR 

1.50004(h)(2); see also Secure Networks Act section 

4(d)(6)(C); see also, e.g., Protecting Against National 

Security Threats to the Communications Supply 

Chain Through FCC Programs, WC Docket No. 18– 

89, Order, DA 23–875, at 1, para. 1 (WCB Sept. 22, 

2023) (granting Stealth Communications Services, 

LLC’s request for extension from September 29, 

2023 until March 29, 2024); Protecting Against 

National Security Threats to the Communications 

Supply Chain Through FCC Programs, WC Docket 

No. 18–89, Order, DA 23–938 (WCB Oct. 10, 2023) 

(granting extension of time requests by WorldCell 

Solutions, LLC, Mediacom Communications 

Corporation, Virginia Everywhere, LLC, James 

Valley Cooperative Telephone Company, and NE 

Colorado Cellular, Inc. d/b/a Viaero Wireless); 

Protecting Against National Security Threats to the 

Communications Supply Chain Through FCC 

Programs, WC Docket No. 18–89, Order, DA 23– 

1016 at 1, para. 1 (WCB Oct. 27, 2023) (granting 

extension of time requests of Point Broadband Fiber 

Holding, LLC and SI Wireless, LLC). 79RWA NPRM Comments at 1, n.3 

(acknowledging that ‘‘RWA members have received 

no specific vendor estimates as to the actual cost 

of compliance’’). 

80 47 CFR 1.925. 

81AT&T NPRM Comments at 3 (‘‘AT&T was able 

to deploy location-based routing to virtually all 

PSAPs within a six-month timeframe.’’). 82See Intrado PN Comments at 10 (‘‘AT&T’s 

implementation model provides a roadmap to the 

other carriers.’’). 

accommodate technology transitions.75

Based on the progress that nationwide 

CMRS providers have made and that 

some non-nationwide CMRS providers 

advocate for a 24-month timeline, it is 

our predictive judgment that the 24 

months afforded will be sufficient from 

both technological feasibility and cost 

perspectives for non-nationwide CMRS 

providers to implement location-based 

routing. If individual CMRS providers 

encounter unique or unusual factual 

circumstances that support a lengthier 

timeline, they may seek a waiver under 

the Commission’s waiver rules.76

49. We decline to extend the timeline 

for compliance for non-nationwide 

CMRS providers to thirty-six months or 

four years, as advocated by RWA and 

CCA, respectively. RWA argues that 

small non-nationwide CMRS providers 

should have 36 months to comply with 

location-based routing requirements 

because they are simultaneously 

focusing ‘‘substantial time and 

attention’’ on replacing network 

equipment under the Secure and 

Trusted Communications Networks 

Reimbursement Program 

(Reimbursement Program), which they 

assert takes ‘‘top priority over regulatory 

compliance unrelated to national 

security.’’ We see no basis for extending 

the 24-month location-based routing 

timeline for non-nationwide CMRS 

providers based on their concurrent 

obligations under the Reimbursement 

Program. Protecting national security 

and ensuring effective 911 emergency 

response are both important regulatory 

obligations that all CMRS providers 

must meet. We reject the view that one 

takes priority over the other. In 

addition, RWA has failed to show how 

the timeline for the Reimbursement 

Program would conflict with nonnationwide provider implementation of 

location-based routing when 

Reimbursement Program removal, 

replacement, and disposal deadlines are 

determined on an application-specific 

basis 77 and may be extended pursuant 

to the conditions set forth in the Secure 

and Trusted Communications Networks 

Act and the Commission’s rules.78

50. RWA also argues that locationbased routing should only be required 

‘‘to the extent that there is federal 

financial support afforded to small 

providers for the cost of compliance and 

additional time afforded for compliance 

beyond that proposed in the NPRM.’’ 

The Commission has never conditioned 

CMRS providers’ compliance with 911 

obligations on the receipt of Federal 

funding and we decline to do so. 

Further, the record does not provide 

compelling evidence that such funding 

is necessary. RWA fails to provide any 

specific estimates as to the actual cost 

of compliance for its members or to 

otherwise document a need for Federal 

financial support.79 Without 

information on the actual cost of 

compliance or specific impacts of such 

compliance on CMRS providers, naked 

claims that Federal financial support is 

necessary in order for CMRS providers 

to comply with the Commission’s 911 

requirements lack merit. As noted 

above, if an individual CMRS provider 

encounters unique or unusual factual 

circumstances, it may seek a waiver 

under the Commission’s waiver rules.80

51. CCA argues that a four-year 

timeline is needed to account for ‘‘levels 

of support the nation’s smaller wireless 

carriers typically receive from device 

makers, technology vendors, and 

software service providers and with the 

continued, incremental progress of 

PSAP systems in all areas of the country 

to support the location-based routing of 

emergency communications.’’ However, 

CCA has not documented the need for 

a four-year timeline as opposed to 

twenty-four months to address the 

specific obstacles faced by these 

providers. Once nationwide CMRS 

providers complete their six-month 

deployment obligation, non-nationwide 

providers will have 18 months to engage 

with device makers, vendors, and 

consultants. In addition, as noted above, 

the timeline is not dependent on PSAPs 

making ‘‘incremental progress’’ to 

support location-based routing because 

PSAPs do not need to take any specific 

technical steps to be ready to receive 

location-based routed calls. 

52. CCA and RWA also argue that 

non-nationwide CMRS providers should 

be afforded a four-year timeline because 

‘‘AT&T required four years to deploy 

location-based routing.’’ We disagree. 

First, AT&T states that it was able to 

deploy location-based routing to 

virtually all PSAPs within six months, 

not four years as asserted by CCA and 

RWA.81 Second, even if AT&T or other 

nationwide CMRS providers took 

additional time to plan early 

implementation of nationwide locationbased routing across their networks, it 

does not follow that non-nationwide 

CMRS providers need the same amount 

of time after the nationwide CMRS 

providers have completed their 

implementations.82 BRETSA notes that 

other providers are likely to require less 

time than AT&T to deploy locationbased routing because ‘‘AT&T has 

already developed the solution and 

provided a roadmap for implementation 

of LBR.’’ In fact, the nationwide CMRS 

providers have already done critical 

work to enable location-based routing 

by adopting highly accurate handsetbased location, which AT&T has 

confirmed ‘‘is available for locationbased routing on the vast majority of 

iOS and Android devices.’’ The 

nationwide carriers have also validated 

that location-based routing can be used 

for the vast majority of wireless 911 

calls and that it does not result in 

additional call delay or an increase in 

abandoned 911 calls. We agree with 

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83CCA NPRM Comments at 2–3. As discussed 

herein, the Commission’s location-based routing 

rules require providers to route on precise location 

information that is available at the network at time 

of routing, which renders moot the potential need 

for call holding. 

84See, e.g., T-Mobile NPRM Comments at 5 

(stating that ‘‘in at least one instance, T-Mobile is 

aware that an emergency calling authority requested 

that another 911 vendor indefinitely suspend using 

LBR for 911 calls to its PSAPs because the vendor’s 

LBR implementation resulted in a greater number 

of 911 calls that required transfer to another 

PSAP’’); AT&T PN Comments at 4 & n.3 (stating that 

AT&T completed its location-based routing 

deployment by the end of June 2022 ‘‘with very few 

exceptions’’ and stating that ‘‘[a] few PSAPs are 

using unique applications of Emergency Services 

Numbers to implement internal routing solutions’’ 

and that AT&T is ‘‘working with these PSAPs to 

ensure [its] location-based routing solution meets 

their unique needs’’). 

85CMRS providers must file such notifications in 

PS Docket No. 18–64. 

86Notice of Proposed Rulemaking, 37 FCC Rcd at 

15197, para. 33. The term ‘‘‘covered text provider’ 

includes all CMRS providers as well as all 

providers of interconnected text messaging services 

that enable consumers to send text messages to and 

receive text messages from all or substantially all 

text-capable U.S. telephone numbers, including 

through the use of applications downloaded or 

otherwise installed on mobile phones.’’ 47 CFR 

9.10(q)(1). 

based routing by nationwide carriers 

‘‘provides ample evidence that LBR will 

soon be ready for wider 

implementation.’’ 

53. CCA also argues that nonnationwide CMRS providers need 

longer timelines to ensure network 

reliability and quality of service before 

undertaking network-wide locationbased routing implementation. Again, 

CCA fails to provide specific examples 

of how non-nationwide CMRS 

providers’ network reliability and 

quality of service would be 

compromised by implementing 

location-based routing within a 24- 

month timeline. CCA also asserts that 

non-nationwide CMRS providers may 

use ‘‘different LTE and 5G–NR network 

specifications’’ than the nationwide 

providers and that it will be challenging 

for non-nationwide CMRS providers to 

implement location-based routing given 

the ‘‘array of potentially viable 

standards any one of which might, over 

time, fail to achieve scale and fall 

behind the other standards in features, 

support, and adoption.’’ We believe a 

24-month timeline is sufficient to 

address these issues. As BRETSA notes, 

non-nationwide CMRS providers have 

not provided specific vendor estimates 

as to the actual cost to implement 

location-based routing. We agree with 

BRETSA that nationwide CMRS 

providers have provided a path for 

implementing location-based routing, 

and there is no reason to delay 

implementation by non-nationwide 

CMRS providers beyond the two years 

afforded. We conclude that the 

considerable benefits of improved 911 

routing should extend to all callers, 

including subscribers to non-nationwide 

CMRS providers’ services, and that 

delaying improved 911 routing by more 

than 24 months would be inequitable 

for these subscribers. 

54. Some entities representing nonnationwide CMRS providers argue that 

location-based routing will provide 

minimal improvement in the areas 

which their members serve, and 

therefore that the Commission either 

should not require location-based 

routing or should further delay 

compliance with location-based routing 

rules for non-nationwide CMRS 

providers. CCA asserts that ‘‘locationbased routing may not provide any 

meaningful improvement over the status 

quo at the cost of dangerously longer 

call set up times’’ for smaller CMRS 

providers that tend to serve less densely 

populated areas.83 Alaska Telecom 

notes that Alaska’s unique situation of 

geography and low population areas 

means fewer misroutes and less benefit 

from location-based routing, such that 

‘‘costs that carriers will bear to 

implement LBR on a short timescale 

will far outstrip the potential benefits.’’ 

We acknowledge that the advantages of 

location-based routing in comparison to 

legacy E911 routing may not be uniform 

across all areas or across all CMRS 

providers. However, we agree with 

Intrado that ‘‘[e]ven in low misroute 

areas, LBR implementation will result in 

a significant reduction in misroutes 

compared to the current system of 

exclusively relying on tower-based 

routing.’’ The benefits of improved 

routing should accrue to all 911 callers 

nationwide, across jurisdictions and 

CMRS providers, and 911 authorities 

have articulated a clear need for 

consistent routing technology across 

CMRS providers. We therefore decline 

to exempt or postpone location-based 

routing implementation on the basis 

that it may provide less benefit in some 

areas than others. 

55. Modification of Deadlines by 

Agreement. We recognize that there may 

be some narrow scenarios in which 

individual PSAPs need additional time 

to facilitate location-based routing.84

AT&T states that while it was able to 

deploy location-based routing to 

virtually all PSAPs within six months, 

‘‘some PSAPs required special attention 

and more time.’’ To provide flexibility 

for PSAPs that request it, we adopt a 

rule allowing a PSAP and a CMRS 

provider to set, by mutual consent, 

deadlines to implement location-based 

routing in the PSAP’s jurisdiction that 

are different from those otherwise 

established by the rules. For example, 

the parties may mutually agree to 

extend the provider’s timeline for 

location-based routing implementation 

in the PSAP’s jurisdiction. We 

emphasize that parties may not use this 

exception to delay implementation and 

deployment of location-based routing 

indefinitely. Accordingly, in the event 

of any agreement to an alternate time 

frame for implementing location-based 

routing, we require the CMRS provider 

to notify the Commission of the agreedto dates within 30 days of the parties’ 

agreement or 30 days from the effective 

date of the final rules, whichever is 

later.85 The CMRS provider must 

subsequently notify the Commission of 

the actual date by which it comes into 

compliance with the location-based 

routing requirements, within 30 days of 

that actual date of compliance or 30 

days from the effective date of the final 

rules, whichever is later. 

2. Text-to-911 

56. We require nationwide and nonnationwide CMRS providers to deploy 

and use location-based routing for RTT 

communications to 911 within 24 

months from the effective date of the 

final rules adopted. This is a 

modification of the rules proposed in 

the notice of proposed rulemaking, 

which would have required CMRS 

providers and all other covered text 

providers to deploy and use locationbased routing for all 911 texts within 18 

months.86 We extend the compliance 

timeline from 18 to 24 months in order 

to align compliance timelines for RTT 

communications to 911 with the 

compliance timelines for nonnationwide providers to implement 

location-based routing for wireless 911 

voice calls. In addition, we limit our 

rules to the routing of RTT 

communications to 911 by CMRS 

providers. We decline at this time to 

extend location-based routing 

requirements to SMS text messages to 

911, both because industry has not yet 

developed standards for implementing 

location-based routing on SMS networks 

and to avoid requiring providers to 

retrofit legacy SMS networks. We 

similarly defer extending location-based 

routing requirements to interconnected 

text providers. 

57. Location-Based Routing for RTT. 

We find that it is technologically 

feasible for CMRS providers to enable 

location-based routing for RTT 

communications. Because RTT is an IPnative service, RTT communications are 

processed on IP-based networks 


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87NENA NPRM Reply at 10. Unlike SMS text-to911, which uses a Text Control Center for routing, 

‘‘RTT uses the existing IP-based voice architecture.’’ 

NENA, NENA PSAP Readiness for Real-Time Text 

(RTT) Information Document, NENA–INF–042.1– 

2021 at 10 (Jan. 20, 2021), https://cdn.ymaws.com/ 

www.nena.org/resource/resmgr/standards/nena-inf042.1-2021_rtt_appv.pdf (NENA RTT Information 

Document). The RTT communication ‘‘enters the 

Common IMS Network via the Proxy/Emergency 

Call Session Control Functions (P/E–CSCF) which 

provide the routing functions.’’ NENA RTT 

Information Document at 13. This is also how 

wireless 911 voice calls originating on IP-based 

networks are processed. See ATIS–0700015.v005 

(‘‘[The P–CSCF] receives the emergency call from 

the User Equipment via the Access Network. The 

P–CSCF detects that the call is an emergency call 

and forwards it to/toward the E–CSCF.’’). Then, 

‘‘[t]he Common IMS Network will acquire location 

using the Location Retrieval Function (LRF) and 

Location Server (LS) and determine the routing 

using the Routing Determination Function (RDF).’’ 

NENA RTT Information Document at 13. Again, this 

is also how wireless 911 voice calls originating on 

IP-based networks are processed. See ATIS– 

0700015.v005 at 24 (‘‘The LRF obtains location 

information associated with the emergency call (by 

interacting with an LS, if necessary) and uses that 

location to acquire routing information for the 

emergency call from the RDF.’’). 

88T-Mobile NPRM Comments at 11 (stating that 

‘‘stakeholders should focus their efforts on 

supporting more robust means of text-based 

communication with PSAPs, including RTT’’); 

Verizon NPRM Comments at 5 (‘‘Verizon’s planned 

LBR implementation for VoLTE will support realtime-text (RTT) 911 calls.’’); NENA NPRM Reply at 

9 (‘‘The Commission’s rules should apply to endto-end RTT calls regardless of NG9–1–1 

capability.’’); ATIS NPRM Comments at 3 (urging 

the Commission ‘‘to clarify that only providers of 

such next generation text solutions [as defined in 

ATIS and NENA standards] are required to use 

LBR’’); see also CTIA NPRM Reply at 8. 

89RTT transition obligations apply to ‘‘those 

entities that are involved in the provision of IPbased wireless voice communication service, and 

only to the extent that their services are subject to 

existing TTY technology support requirements 

under Parts 6, 7, 14, 20, or 64 of the Commission’s 

rules.’’ RTT Order, 31 FCC Rcd at 13576–77, para. 

12. The Commission requires CMRS providers 

transmitting over an IP network that choose to 

enable the transmission and receipt of 

communications via RTT, in lieu of TTY 

technology, to and from any PSAP served by their 

network, to enable such service in a manner that 

fully complies with all applicable 911 rules. Id. at 

13591–92, para. 43. PSAPs require special 

capabilities to receive RTT communications from 

CMRS providers. Id. at 13592, para. 43. We 

recognize that many PSAPs are not currently 

capable of supporting RTT communications and 

remain reliant on TTY technology to receive calls 

from people with disabilities. Texas 9–1–1 Entities 

NPRM Comments at 5; see RTT Order at 13592, 

para. 43; FCC, What Public Safety Answering Points 

Should Know about Real-Time Text at 2 (Oct. 2, 

2018), https://www.fcc.gov/sites/default/files/ 

documents/events/fact_sheet_about_real-time_text_

for_public_safety_answering_points.pdf. 

90 Verizon does comment on RTT specifically and 

distinguishes it from other 911 texting, with an 

indication that it may be easier for Verizon to 

implement RTT than SMS location-based routing. 

Verizon states that ‘‘[w]hile Verizon’s planned LBR 

implementation for VoLTE will support real-timetext (RTT) 911 calls, LBR for SMS is not feasible 

using our existing platforms and capabilities, and 

would require substantial network- and device-level 

changes and upgrades.’’ Verizon NPRM Comments 

at 5. 

91See, e.g., iCERT NPRM Comments at 2 

(supporting 18-month timeline for all covered text 

providers, ‘‘without regard to service area’’); NENA 

NPRM Comments at 1; AT&T NPRM Comments at 

6 (supporting 18-month compliance timetable, but 

conditioned on PSAP request and readiness). 

92 Verizon NPRM Reply at 2; see also, e.g., RWA 

NPRM Comments at 3 (indicating smaller providers 

need more time to comply than larger providers, 

and requesting small rural providers be given 36 

months from the effective date of the rules to 

implement text-to-911, ‘‘and then only if the PSAP 

is capable of handling the call routing’’); Southern 

Linc NPRM Reply at 6–8 (stating that if Commission 

requires location-based routing for SMS-based texts 

to 911, nationwide CMRS providers should have at 

least 18–24 months from the effective date of the 

rules and non-nationwide CMRS providers should 

have an additional 12–18 months beyond that, in 

recognition of smaller carriers’ ‘‘additional 

challenges and resource constraints’’ and that a 

CMRS provider’s obligation to commence use 

should only be triggered by a valid request from the 

PSAP or other relevant authority). 

93See Donny Jackson, APCO speakers say RTT 

being used operationally, could be key platform for 

911 in the future, IWCE’s Urgent Communications 

(Aug. 8, 2023), https://urgentcomm.com/2023/08/ 

08/apco-speakers-say-rtt-being-used-operationallycould-be-key-platform-for-911-in-the-future/ 

(Jackson, APCO speakers) (noting 911 officials 

stress the ‘‘nascent operation of RTT for emergency 

calling, as only a handful of PSAPs are using the 

technology at the moment’’). 

similarly to voice calls originating on IPbased networks. According to NENA, an 

RTT session is ‘‘handled and routed the 

same way as a voice call and delivers 

location just as a voice call would.’’ 87

We agree with NENA that our rules 

‘‘should reflect this reality.’’ In addition, 

because RTT resembles voice calling in 

that it is a real-time, two-way service, 

the user experience of RTT is likely to 

be similarly sensitive to the delays 

associated with misroutes. Given the 

technical similarities with processing 

voice calls originating on IP-based 

networks and strong support for 

implementing requirements for locationbased routing for text-to-911 as a general 

matter, we adopt a requirement for 

location-based routing for RTT 

communications to 911 consistent with 

the requirements we adopt for wireless 

911 voice calls originating on IP-based 

CMRS networks. In addition, 

commenters specifically support 

location-based routing for RTT 

communications.88 CMRS providers 

urge the Commission to incentivize both 

PSAPs and CMRS providers to move 

toward next generation texting 

technologies such as RTT. We find that 

these requirements will help to ensure 

that the benefits of location-based 

routing extend to RTT users as more 

CMRS providers implement RTT 

service. We note that this rule is not 

intended to expand CMRS providers’ 

existing obligations to deploy RTT 

capabilities to PSAPs beyond what is 

already required by the Commission.89

58. Compliance Deadlines for 

Location-Based Routing for RTT. We 

require CMRS providers to implement 

location-based routing for RTT within 

24 months after the effective date of the 

final rules on location-based routing. 

This timeline is six months longer than 

the eighteen-month period the 

Commission proposed in the notice of 

proposed rulemaking for all covered text 

providers to route all texts to 911. Most 

of the comments received on timelines 

address 911 texts in general, without 

specifically addressing issues related to 

RTT implementation in particular.90

Some commenters support the 

originally proposed 18-month timeline 

for text-to 911,91 while others support a 

shorter timeline. NASNA suggests that 

‘‘it may be more appropriate to apply 

the same implementation timeframes for 

911 texts that are being applied to voice 

911 calls.’’ Other commenters urge that 

covered text providers be given a longer 

timeline to implement location-based 

routing. For example, Verizon notes that 

several parties echo its own comments 

regarding the need for a longer 

implementation period for 911 texts. 

Verizon ‘‘expects that an 

implementation period of 18–24 months 

for a ‘best available location’ approach 

could be technically feasible, provided 

that the rules afford wireless providers 

flexibility in the location query methods 

and per-call thresholds governing 

whether precise versus coarse location 

is used for routing.’’ 92

59. We conclude that a timeline of 24 

months after the effective date of the 

rules is technically feasible for CMRS 

providers to implement location-based 

routing for RTT. We also believe that 24 

months will provide sufficient time for 

both nationwide and non-nationwide 

CMRS providers to implement locationbased routing for RTT. We decline to 

adopt a shorter timeline for nationwide 

CMRS providers and instead opt, 

consistent with the notice of proposed 

rulemaking, to apply the same timetable 

to all providers for implementation of 

location-based routing for RTT 

communications. Unlike for 911 voice 

calls, the extent to which nationwide 

CMRS providers have implemented 

location-based routing for RTT is not 

clear, though we note that T-Mobile and 

Verizon explicitly support this step. In 

addition, few PSAPs have developed the 

capability to receive end-to-end RTT 

communications.93 Since RTT remains 

in the early stages of development, we 

believe that a unified timeline for 

nationwide and non-nationwide CMRS 

providers is consistent with the 

approach in the Commission’s existing 

text-to-911 rules, which do not 

distinguish between nationwide and 


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94See 47 CFR 9.10(q)(1), (10). 

95COPUC NPRM Comments at 8; BRETSA NPRM 

Reply at 8; NASNA NPRM Comments at 13. DISA 

also argues that location-based routing for text-to911 could also decrease the response time for 911 

texts originating outside the three-mile line off U.S. 

and Territorial shores. DISA NPRM Comments at 1. 

96 Verizon NPRM Comments at 5; Southern Linc 

NPRM Reply at 7; NENA NPRM Reply at 9, n.41; 

ATIS NPRM Comments at 3. ATIS/TIA J-STD110.v002 defines the requirements, architecture, 

and procedures for text messaging to 911 emergency 

services using native wireless operator SMS 

capabilities for the existing and NG911 PSAPs. 

ATIS and Telecommunications Industry 

Association (TIA), Joint ATIS/TIA Native SMS/ 

MMS Text to 9–1–1 Requirements and Architecture 

Specification—Release 2 at sections 7, 8, and 9 

(May 2015), https://webstore.ansi.org/standards/ 

atis/std110 (ATIS/TIA J–STD–110.v002). In 2014, 

the Commission explained that ‘‘The scope of the 

J–STD–110 is limited to text messaging to 9–1–1 for 

native SMS capabilities, and it does not address 

support of text-to-911 for interconnected text 

services using ‘over-the-top’ SMS.’’ T911 Second 

Report and Order, 29 FCC Rcd at 9864, para. 39 

n.106 (citing to a previous version of ATIS/TIA J– 

STD–110, Section 1.1). 

97As of December 2023, the Commission’s Textto-911 Registry lists 3,201 PSAPs as text-capable. 

See FCC, PSAP Text-to-911 Readiness and 

Certification Registry, https://www.fcc.gov/general/ 

psap-text-911-readiness-and-certification-form. In 

calendar year 2022, U.S. PSAPs received a 

combined total of 824,609 texts to 911 in 

comparison to 157,999,298 wireless 911 voice calls. 

Fifteenth Annual 911 Fee Report at 13–16, Table 3. 

98See AT&T PN Comments at 5 (describing 

AT&T’s location-based routing for text-to-911 

implementation); T-Mobile July 26, 2023 Ex Parte 

at 3; Verizon Dec. 7, 2023 Ex Parte at 1. NENA also 

states ‘‘There are non-standards-based mechanisms 

for supporting location-based routing for interim 

text 156 which are available and in-use in the 

market today.’’ NENA NPRM Reply at 9. 

99 47 CFR 9.10(q)(10)(i). 

100T911 Second Report and Order, 29 FCC Rcd 

at 9874, para. 57 (‘‘We require covered text 

providers to route texts to 911 using coarse location 

(cell ID and cell sector) or other equivalent means 

that allows the covered text provider to route a text 

to the appropriate PSAP.’’). 

non-nationwide CMRS providers.94 In 

addition, given that RTT uses call 

processing similar to that used for voice 

calls, we anticipate that non-nationwide 

CMRS providers will be able to 

implement this capability on the same 

timeline as location-based routing for 

voice calls originating on IP-based 

networks. However, we encourage 

CMRS providers (nationwide or nonnationwide) to adopt location-based 

routing for RTT before the 24-month 

deadline if feasible. 

60. Location-based routing for SMS. 

Some public safety commenters urge the 

Commission to require location-based 

routing for all texts to 911, including 

SMS, so that improved text routing is 

available to individuals who are deaf, 

hard of hearing, or have speech related 

disabilities, and to people in situations 

where the sound of a voice call would 

place them in peril.95 We agree with 

public safety commenters that locationbased routing could provide benefits to 

communities that rely on text messaging 

to contact 911. However, we decline to 

require location-based routing for SMS 

messages at this time because the record 

indicates that industry has not yet 

developed standards for implementing 

location-based routing on SMS networks 

and because of the potential cost of 

requiring covered text providers to 

retrofit legacy SMS networks. 

61. In particular, commenters note 

that enabling location-based routing for 

SMS would require updates to the 

relevant technical standard, ATIS/TIA 

J–STD–110.96 According to NENA, 

implementing standards-based SMS 

solutions would add at least two years 

for standards development, product 

development, and deployment. TMobile, Alaska Telecom, and Verizon 

also note that implementing locationbased routing for SMS would require 

potentially costly retrofitting of legacy 

SMS networks. Verizon argues that 

enabling location-based routing for SMS 

‘‘would require substantial upgrades of 

Short Message Service Center (SMSC) 

and Text Control Center (TCC) facilities 

. . . and device changes to enable the 

device to override security, privacy and 

other functions to access the caller’s 

device-level location information.’’ In 

addition, Verizon argues that requiring 

location-based routing for SMS could 

impose duplicative cost and 

implementation burdens that would be 

unnecessary once a jurisdiction 

launches i3 NG911 capabilities. We also 

note that some PSAPs remain incapable 

of receiving texts and that the volume of 

911 texts is far smaller than volume of 

wireless 911 voice calls.97 In light of 

these factors, we find that it would not 

serve the public interest to require 

CMRS providers to retrofit legacy SMS 

networks. 

62. We recognize that the three 

nationwide CMRS providers are using 

non-standardized location-based routing 

techniques to route some SMS texts to 

911 today.98 We encourage all CMRS 

providers to deploy location-based 

routing for SMS messages voluntarily to 

the extent that their resources permit, 

and we intend to monitor the 

development of standards, products, 

and other advances affecting locationbased routing for SMS text-to-911. 

However, we agree with NENA that ‘‘the 

Commission’s rules should not back the 

market into adopting non-standardized 

technologies for a legacy platform that 

the industry is actively working to 

phase out.’’ 

63. We decline to adopt commenters’ 

alternative proposal to require CMRS 

providers to route SMS text messages 

using ‘‘best available’’ location 

information. Instead of a tiered system, 

in which CMRS providers would use 

precise location information within a 

radius of 165 meters at a 90% 

confidence level and otherwise default 

to best available location information, 

these commenters suggest a requirement 

to route SMS text messages based on 

best available location information (i.e., 

there would be no requirement to use 

highly precise location information 

when it is available from the handset). 

Intrado argues that, unlike wireless 911 

voice calls to 911, for SMS ‘‘there is no 

fallback information available for text 

and no technologic way or need to 

implement LBR for text differently nor 

any means to apply a specific 

uncertainty/confidence requirement 

. . . .’’ As with the proposed 

requirement to route text messages 

when available location information 

meets our accuracy and timeliness 

criteria, solutions that route using ‘‘best 

available’’ location information are still 

not standards-based. Therefore, we 

decline to require CMRS providers to 

implement non-standard location-based 

routing solutions for SMS text messages 

at this time. The Commission may 

reconsider if applicable standards are 

developed. 

64. Under the Commission’s existing 

text-to-911 rules, ‘‘covered text 

providers must obtain location 

information sufficient to route text 

messages to the same PSAP to which a 

911 voice call would be routed, unless 

the responsible local or state entity 

designates a different PSAP to receive 

911 text messages . . . .’’ 99 The 

implementation of location-based 

routing, which uses more precise 

location information than the towerbased routing method, may change the 

PSAP to which a 911 voice call would 

otherwise be routed. We do not interpret 

this provision to require covered text 

providers to obtain the same precise 

location information for SMS or other 

non-RTT text messages that would be 

used for a voice call subject to the 

Commission’s location-based routing 

rules. Instead, this provision would 

continue to require covered text 

providers to obtain location information 

sufficient to route text messages (other 

than RTT) to the same PSAP to which 

a wireless 911 voice call would be 

routed using coarse location or other 

equivalent means, the routing 

technology in use at the time of 

adoption of this rule.100

65. Location-based routing for other 

text-messaging platforms. We decline to 

consider location-based routing for 

other types of text-messaging platforms, 

such as Multimedia Messaging Service 


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101See, e.g., GCI July 17, 2023 Ex Parte at 1 (‘‘LBR 

for SMS/MMS text-to-911 would be much more 

difficult than for IP-originated wireless calls 

. . . .’’); NENA NPRM Reply at 8 (discussing that 

‘‘interim text uses SMS/MMS for emergency text 

calls’’); Intrado NPRM Comments at 4 (discussing 

‘‘SMS/MMS design’’). 

102NG911 Notice of Proposed Rulemaking at *20, 

para. 51. For example, commenters discussed 

definitions for the terms ‘‘NG911,’’ ‘‘ ‘IP-based’ 

911,’’ and ‘‘NG911-capable PSAPs,’’ which we 

believe would be better addressed in the NG911 

proceeding so as to apply to a wider array of 911 

originating service providers. See APCO NPRM 

Comments at 5; CTIA NPRM Comments at 8; 

Southern Linc NPRM Reply at 8–9; NENA NPRM 

Reply at 4–5, 7–8. 

103NASNA NPRM Comments at 14; COPUC 

NPRM Comments at 8; Alaska Telecom NPRM 

Reply at 4 (noting also that Alaska Telecom 

‘‘believes that it is important that ‘location’ be 

limited to the autonomous location derived by the 

device, with accuracy based on what is coming 

from the device, not information derived by the 

carrier network’’). 

104APCO NPRM Comments at 4. APCO does not 

specifically identify what such ‘‘unintentional 

limitations’’ are, but cites to its discussion of ‘‘the 

current state of ESInet capabilities.’’ APCO NPRM 

Comments at 4, n.20. APCO asserts that ‘‘ESInets 

may or may not be capable of performing locationbased routing after receiving the call from a wireless 

service provider. Thus, the NPRM’s consideration 

of ‘NG9–1–1 capabilities’ and ESInets as factors for 

the location-based routing requirements raises 

concerns. The Commission can and should adopt 

location-based routing requirements without 

considering ‘NG9–1–1’ progress or ESInet 

deployment.’’ Id. at 6. 

105AT&T NPRM Comments at 8. However, AT&T 

also states that ‘‘individual states and PSAP 

authorities can designate ESInets as an endpoint for 

the delivery of 911 calls[,]’’ and ‘‘encourages the 

Commission . . . to confirm that states and local 

jurisdictions have this authority.’’ Id. 

106AT&T NPRM Comments at 3–4 (citing 

Commission’s wording in the notice of proposed 

rulemaking); see also Alaska Telecom NPRM Reply 

at 4 (supporting Commission’s proposed definition 

as allowing for technological development and 

improvement over time); NENA NPRM Reply at 4 

(citing AT&T NPRM Comments at 3–4). 

(MMS) platforms, at this time. To the 

extent that commenters discussed other 

text messaging platforms, such 

comments combined arguments 

regarding SMS and MMS platforms.101

As discussed herein, MMS platforms 

rely on many of the same functional 

network elements that would be used to 

process SMS messages. We therefore 

decline to consider requirements for 

location-based routing for MMS for the 

same reasons discussed in this section 

for SMS text. We also decline 

consideration of location-based routing 

for over-the-top (OTT) platforms, as no 

commenter discussed OTT platforms. 

3. Definitions 

66. In the notice of proposed 

rulemaking, the Commission proposed 

to define ‘‘location-based routing’’ as 

routing based on the location of the 

calling device rather than the location of 

network elements such as cell site or 

sector. The Commission also proposed a 

definition of ‘‘device-based location 

information’’ and sought comment on 

whether the definition adequately 

encompasses current and future location 

technologies. We adopt these definitions 

as proposed and find that they will add 

clarity to the rules while remaining 

flexible and allowing for the future 

evolution of new technologies. We defer 

consideration of the proposed 

definitions of other terms relating to IP 

delivery for NG911 networks to the 

separate NG911 transition proceeding in 

PS Docket No. 21–479.102

67. Location-Based Routing. The 

notice of proposed rulemaking proposed 

to define ‘‘location-based routing’’ as the 

use of information on the location of a 

device, including but not limited to 

device-based location information, to 

deliver 911 calls and texts to point(s) 

designated by the authorized local or 

state entity to receive wireless 911 calls 

and texts, such as an Emergency 

Services internet Protocol Network 

(ESInet) or PSAP, or to an appropriate 

local emergency authority. Most 

commenters addressing the issue, 

including NASNA, NENA, COPUC, and 

Alaska Telecom, support the proposed 

definition.103 Alaska Telecom states that 

the proposed definition is flexible and 

‘‘will give carriers, 911 vendors, and 

public safety entities the ability to 

invest time and resources into new and 

improved location technologies.’’ 

68. APCO and AT&T suggest that the 

definition avoid reference to ‘‘devicebased location information’’ or to 

ESInets. APCO states that it does not 

disagree with the assumption that 

ESInets may be a potential delivery 

point for 911 calls, but contends that ‘‘a 

simpler approach that does not 

reference ESInets could avoid 

unintentional limitations.’’ 104 AT&T 

argues that identifying ESInets as end 

points that state or local 911 authorities 

can designate is outside the scope of the 

proceeding and unnecessary.105 NENA 

and Alaska Telecom oppose narrowing 

the definition, and DISA and COPUC 

support including ESInets as an 

illustrative example. Alaska Telecom 

states that ‘‘[t]he Commission’s 

proposed definition allows for 

technological development and 

improvement over time, in contrast to 

the changes suggested by APCO’’ to 

define ‘‘location-based routing’’ by 

reference to uncertainty and confidence 

metrics. 

69. We adopt the proposed definition 

in order to provide guidance to 

regulated entities on how to comply 

with our location-based routing rules. 

This definition of location-based routing 

does not extend to tower-based routing 

methodologies. We disagree with APCO 

that referring to ESInets in the rules as 

an illustrative example could 

unintentionally limit the location-based 

routing definition. APCO objects to 

referencing ESInets in the definition 

because ‘‘ESInets may or may not be 

capable of performing location-based 

routing.’’ However, the term is used in 

the definition merely to identify ESInets 

as a potential delivery point for 911 

voice calls and RTT communications, 

without any reference to the technical 

capabilities of ESInets. Including 

ESInets as an illustrative example 

clarifies that providers can use locationbased routing to deliver 911 calls to 

ESInets, without precluding or limiting 

use of other network architectures and 

end points. We similarly disagree with 

the view that use of the term ‘‘devicebased location information’’ in the 

definition is too limiting. Again, the 

term is included as an illustrative 

example rather than a technological 

restriction. Thus, location technologies 

that do not use device-based location 

information may also fall within the 

scope of the location-based routing 

definition. 

70. Device-Based Location 

Information. The notice of proposed 

rulemaking proposed to define ‘‘devicebased location information’’ as 

‘‘[i]nformation regarding the location of 

a device used to call or text 911 

generated all or in part from on-device 

sensors and data sources.’’ The 

Commission noted that this term is used 

in the existing rule on delivery of 911 

text messages and that the proposed 

definition would also apply to that rule. 

We conclude that this definition of 

‘‘device-based location information’’ 

provides useful guidance to regulated 

entities for compliance with the 

location-based routing rules, while 

remaining flexible enough to account for 

future technological development. 

COPUC supports the definition 

proposed in the notice of proposed 

rulemaking. Several other commenters 

urge the Commission to ensure that the 

definition is flexible enough to 

encompass current and future 

technologies.106 We find that the 

definition is sufficiently broad and 

flexible to meet this goal. 

71. We also decline to adopt several 

suggestions from the record to modify 

the definition of ‘‘device-based location 

information.’’ AT&T supports ‘‘a 

definition of ‘device-based location 

information’ that is tied to timeliness 

and accuracy metrics . . . .’’ However, 

the ‘‘device-based location information’’ 

definition is intended to describe a 

mechanism for deriving location 


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107For CMRS providers, ‘‘all 911 calls’’ include 

‘‘those [911 calls CMRS providers] are required to 

transmit pursuant to subpart C of this part [9].’’ 47 

CFR 9.3. This definition therefore extends to texts, 

which are subject to 47 CFR 9.10(q), a provision 

which resides in subpart C of part 9 of the 

Commission’s rules. In this document, we 

distinguish between 911 wireless voice calls, 911 

texts, and RTT communications for the sake of 

precision. However, we preserve the language from 

the notice of proposed rulemaking for the purposes 

of this paragraph. 

108See Notice of Proposed Rulemaking, 37 FCC 

Rcd at 15199, para. 38 (citing Intrado PN Comments 

at 6, 8; Apple Sept. 24, 2019 Ex Parte at 2; and 

Android, Emergency Location Service—How It 

Works, https://www.android.com/safety/emergencyhelp/emergency-location-service/how-it-works/ (last 

visited Jan. 17, 2024)); Verizon NPRM Comments at 

6 (stating that RTT ‘‘will also benefit from the same 

routing improvements and advantages as i3 voice 

calls’’); NENA NPRM Comments at 12 (stating that 

an RTT communication in NG911 ‘‘requires no 

special handling compared [to] a ‘conventional’ 

voice call’’). 

109AT&T has used location-based routing for over 

80% of all AT&T wireless calls. Intrado PN 

Comments at 2. Intrado further notes that AT&T’s 

location-based routing solution provides locationbased routing ‘‘without any impact to the timeline 

or call.’’ Intrado PN Comments at 6. 

110T-Mobile indicates that more than 95% of 

location estimates available at call routing on TMobile’s network fall within the company’s 

threshold, i.e., ‘‘300 meters with a confidence level 

of 90%.’’ T-Mobile July 26, 2023 Ex Parte at 1. 

111See Verizon July 13, 2023 Ex Parte at 1 (‘‘To 

determine whether device-based hybrid location 

information provided by the device during a call is 

adequate for routing, Verizon uses an accuracy 

threshold of 200 meters maximum horizontal 

uncertainty with confidence of 90 percent.’’). 

112Notice of Proposed Rulemaking, 37 FCC Rcd 

at 15191, para. 16. See also Android, Emergency 

Location Service—How It Works, https://

www.android.com/safety/emergency-help/ 

emergency-location-service/how-it-works/ (last 

visited Jan. 17, 2024) (‘‘On average, ELS is able to 

get a first location 3–4 seconds after the call has 

started.’’); Android, Emergency Location Service— 

Overview, https://www.android.com/safety/ 

emergency-help/emergency-location-service/ (last 

visited Jan. 17, 2024) (‘‘ELS works on over 99% of 

active Android devices running OS4.4 and up, with 

Google Play Services installed-no new hardware or 

activation required.’’); Apple Sept. 24, 2019 Ex 

Parte at 2 (indicating that device-based hybrid 

location is available from certain devices during 

call set-up and that location-based routing can be 

enabled on models 6s and later running iOS 13 and 

Apple Watch devices running watch OS 6). 

113NASNA NPRM Comments at 14; see also 

COPUC NPRM Comments at 6–7; iCERT NPRM 

Comments at 3 (‘‘[W]e support the FCC’s proposal 

to require use of LBR when the wireless network 

provider can determine the location of the caller 

within the recommended five-second window. If 

the caller’s location is not available within this 

timeframe, the provider should use traditional cell 

site-based methods.’’); see also BRETSA NPRM 

Reply at 14–15 (arguing that minimum hold times 

might increase the percentage of calls that can be 

routed on device-based hybrid location information 

where providers still operate 3G networks, or that 

911 authorities may wish to participate in tests to 

determine whether holding calls would allow for 

additional calls on IP-based networks to be routed 

using location-based routing). 

information rather than determining the 

timeliness or accuracy of the 

information. In addition, we separately 

set forth timeliness and accuracy 

metrics elsewhere in the rules. DISA 

suggests adding language to indicate 

that the location is to be determined ‘‘at 

origination (setup) of [a] voice call.’’ We 

decline to adopt this suggested change, 

as the issue of timeliness of the location 

information used for location-based 

routing is addressed in other rules we 

adopt. 

4. Timeliness and Accuracy of LocationBased Routing Information 

72. We require CMRS providers to use 

location-based routing for wireless 911 

voice calls and RTT communications to 

911 when the location information 

available to the CMRS provider’s 

network at time of routing is 

ascertainable within a radius of 165 

meters at a confidence level of at least 

90%. We anticipate that a substantial 

percentage of wireless 911 voice calls 

and RTT communications to 911 will 

route on location information meeting 

the accuracy and timeliness threshold 

under the rules adopted. If location 

information meeting this threshold is 

not available at the time of routing, we 

require CMRS providers to use the ‘‘best 

available’’ location information for 

routing wireless 911 voice calls and 

RTT communications to 911. Such ‘‘best 

available’’ location information may 

include but is not limited to devicebased location information that does not 

meet the accuracy threshold, towerbased location information (e.g., the 

centroid of the area served by the cell 

sector that first picks up the call), or 

other location information. The 

requirements we adopt are those 

proposed in the notice of proposed 

rulemaking with slight definitional 

modifications. 

a. Timeliness Threshold 

73. As noted in the notice of proposed 

rulemaking, location-based routing 

requires information about the caller’s 

location to be available quickly enough 

to enable the call to be routed without 

delaying the normal call set-up process. 

We adopt the Commission’s proposal 

from the notice of proposed rulemaking 

to require the use of location-based 

routing only if caller location 

information is available to the CMRS 

provider network at the time that the 

CMRS provider would otherwise route 

the call.107 This timeliness threshold is 

intended to avoid delay in transmitting 

wireless 911 voice calls and RTT 

communications to PSAPs. 

74. The record indicates that currently 

available technology is routinely 

capable of delivering location 

information to CMRS provider networks 

for wireless 911 voice calls and RTT 

communications to 911 in time for 

routing without delay.108 Nationwide 

CMRS providers’ implementations have 

demonstrated that obtaining such 

location in time for routing is feasible. 

Devices that are capable of producing 

high accuracy, low latency location for 

emergency calling are in wide use, and 

IP network technology supports rapidly 

obtaining such precise location 

estimates. The location-based routing 

deployments of AT&T,109 T-Mobile,110

and Verizon 111 demonstrate that precise 

location information can be made 

routinely available to CMRS providers’ 

networks in time for routing wireless 

911 voice calls. Both Android devices 

using ELS and iOS devices using HELO 

are capable of generating high accuracy, 

low latency location information in time 

to support 911 call routing.112

Moreover, iOS and Android devices 

account for 99.62% of the U.S. device 

market, meaning that this capability is 

widely available to consumers. Intrado 

states that 4G LTE and newer networks 

can obtain device-based location 

information, calculate confidence and 

uncertainty, and query the location 

server for PSAP routing instructions 

within the normal call set-up interval. 

T-Mobile states that the ‘‘IP Multimedia 

Subsystem (‘IMS’) technology and 

advancement of device-based hybrid 

location solutions has enabled the use of 

a caller’s estimated device location for 

call routing without delaying call setup.’’ 

75. Some commenters suggest that the 

Commission should require CMRS 

providers to route 911 calls within five 

seconds to ‘‘prevent a CMRS provider 

from holding onto a call for eight to ten 

seconds or even longer waiting for a 

location fix.’’ 113 We decline to adopt 

this requirement because doing so could 

incentivize CMRS providers to hold 

wireless 911 voice calls and RTT 

communications to 911 for the full five 

seconds when location information does 

not meet the threshold for accuracy, 

which could result in delays for 

wireless 911 voice calls and RTT 

communications to 911. The 

requirement that location information 

be available at time of routing, as the 

Commission stated in the notice of 

proposed rulemaking, ‘‘is intended to 

avoid delay in transmitting 911 calls 

and texts because there would be no 

requirement to hold calls and texts for 

purposes of obtaining a routing fix.’’ 

Intrado points out that deploying 

location-based routing under the 

Commission’s proposed framework 

‘‘renders moot the potential need for 

call holding.’’ We agree that the 

framework as adopted avoids 


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114APCO NPRM Comments at 2; Adams County 

et al. NPRM Comments at 3 (‘‘The proposed 

confidence levels are acceptable, but ideally, over 

time, the radiuses and confidence levels in the 

proposed rule should be tightened so that 911 calls 

are routed more precisely.’’); BRETSA NPRM 

Comments at 8 (‘‘Intrado has found that LBR from 

hybrid device location information will allow 

accurate routing of wireless 9–1–1 calls over 80 

percent of the time using thresholds of 165 meters 

and a 90 percent confidence level. The Commission 

should require national and regional wireless 

providers [to] implement LBR at the earliest 

possible time.’’ (Footnote omitted, citing Intrado PN 

Comments at 9)); Intrado NPRM Comments at 5. 

115CTIA NPRM Comments at 5; T-Mobile NPRM 

Comments at 10; Verizon NPRM Comments at 3; 

ATIS NPRM Comments at 3–4; see also Southern 

Linc NPRM Reply at 5–6 (agreeing with ATIS, TMobile, Verizon, and CTIA that it is premature to 

adopt specific metrics). 

116ATIS NPRM Comments at 4. We note that a 

location accuracy threshold with a radius of 300 

meters would also be an acceptable location-based 

routing implementation under the rules we adopt. 

117T-Mobile July 26, 2023 Ex Parte at 2; T-Mobile 

NPRM Reply at 3–4; T-Mobile NPRM Comments at 

9; see also ATIS NPRM Comments at 4 (‘‘[T]he 

Commission should defer to the recommendations 

regarding the feasibility of location accuracy from 

industry groups such as ATIS ESIF.’’). 

introducing new delays for wireless 911 

voice calls and RTT communications to 

911. Conversely, if we were to set a 

maximum five-second time frame for 

routing, it could incentivize CMRS 

providers to hold calls and RTT 

communications at the network for the 

full five-second window to ensure 

routing based on ‘‘best available’’ 

location. This in turn could create 

delays in connecting callers to a PSAP 

and cause some callers to terminate 

their 911 calls. To avoid such adverse 

impacts, we decline to set a maximum 

time frame for routing wireless 911 

voice calls or RTT communications to 

911. 

76. We also decline to specify, as 

suggested by DISA, that the location 

information used for routing be 

determined ‘‘at origination (setup) of [a] 

voice call.’’ While we expect that 

location for most calls will be 

determined at origination, DISA’s 

proposal could inadvertently be too 

restrictive, if location were to arrive 

after the setup of a voice call but before 

routing. We believe it is sufficient to 

require only that location information 

be available at the time of call routing, 

regardless of when the location is 

determined. 

77. NGA 911 asserts that a timeliness 

requirement ‘‘appears to leave a big gap 

in the implementation because a carrier 

may always be able to claim the 

information was not available at time of 

call routing.’’ The record indicates, 

however, that CMRS providers are 

already deploying technology that 

routinely provides the required location 

information at the time of call routing 

with no delay. For example, Intrado 

states that in AT&T’s network, location 

information meeting the threshold is 

available in time to route wireless 911 

voice calls 80% of the time, and that 

routing on the network ‘‘requires no call 

delay.’’ We intend to monitor the 

deployment and use of location-based 

routing on CMRS provider networks 

with reporting requirements discussed 

herein. Should we learn that some 

CMRS providers are not taking full 

advantage of available technology that 

provides location-based routing 

information at the time of the call, we 

will consider whether additional 

measures are needed. 

b. Accuracy Threshold 

78. Turning to the required accuracy 

threshold for location-based routing, we 

adopt the requirement that CMRS 

providers use location-based routing to 

route wireless 911 voice calls and RTT 

communications to 911 if the location 

information available at the time of 

routing identifies the horizontal location 

of the device within a radius of 165 

meters at a confidence level of at least 

90%. This requirement is consistent 

with the requirement the Commission 

proposed in the notice of proposed 

rulemaking. 

79. We adopt the 165-meter threshold 

with a confidence level of at least 90% 

in light of the demonstrated efficacy of 

location-based routing using such a 

threshold and because this threshold 

provides enough flexibility to be 

compatible with nationwide CMRS 

providers’ existing implementations of 

location-based routing. We believe that 

this location accuracy threshold will 

substantially reduce the number of 

misroutes associated with legacy E911 

routing. AT&T has applied a location 

accuracy threshold with a radius of 165 

meters at a confidence level of 90% in 

its own network. Intrado states that 

location information meeting this 

location accuracy threshold is available 

to AT&T’s network to route calls 80% of 

the time, and most calls route on 

information that identifies the location 

of the device within 50 meters. As a 

result, AT&T’s solution ‘‘provid[es] a 

more optimal route than sector-based 

routing for approximately 10% of all 

wireless 911 calls’’ and ‘‘[t]herefore, 

10% of calls will be getting to the 

correct PSAP on the first try and will 

not require transfers from the 

neighboring PSAP.’’ 

80. We agree with public safety 

entities and Intrado that it is imperative 

that we set an accuracy threshold that 

is realistic in light of existing 

technology while also providing room 

for future technological 

improvement.114 APCO supports the 

proposed location accuracy threshold 

but remains open to an alternative that 

‘‘strikes an appropriate balance between 

how often the device’s location will be 

known quickly and accurately enough 

to use location-based routing rather than 

cell-sector based routing, and how 

effective the use of location-based 

routing will be at delivering the call to 

the correct ECC [emergency 

communications center].’’ AT&T 

supports a location accuracy threshold 

‘‘that the Commission believes would 

represent a significant improvement 

over cell-based routing methodologies.’’ 

81. Some wireless industry 

commenters oppose the proposed 

location accuracy threshold and claim 

that additional flexibility is needed for 

providers to set individualized 

thresholds.115 Verizon argues that a 

rigid location accuracy threshold is 

unnecessary to meet the Commission’s 

public safety objectives and that any 

particular location accuracy threshold 

should at most serve as a safe harbor. 

ATIS asserts that providers should 

‘‘strive’’ but not be mandated to produce 

location information for purposes of 

routing within a radius of 300 meters or 

less at a confidence level of 90%.116

ATIS also asserts that it is developing 

best practices for carriers to implement 

location-based routing, and T-Mobile 

states that the Commission should wait 

for these best practices before requiring 

specific distance and confidence metrics 

for location-based routing.117 We 

encourage ATIS to conclude any such 

efforts on a timeline that is consistent 

with the requirements adopted. 

82. We conclude that a mandatory 

threshold is necessary. The accuracy 

threshold we set ensures that all CMRS 

providers will use location-based 

routing nationwide for 911 calls and 

RTT communications to 911 when 

location information at the time of 

routing meets a high accuracy standard. 

We also disagree that there is a need to 

wait for the development of best 

practices, as the location-based routing 

rules we adopt require CMRS providers 

to use this methodology when the 

location information available to the 

network is highly accurate, and further 

permit CMRS providers to use locationbased routing methodologies in 

additional scenarios. We observe that 

the nationwide CMRS providers have all 

completed or are currently 

implementing location-based routing on 

their IP-based networks, and all use 

location-based routing to route wireless 

911 voice calls when available location 

meets this mandatory threshold for 


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118 Verizon and T-Mobile also use location-based 

routing for less precise location estimates. 

119 Intrado notes that AT&T’s threshold is 165 

meters at a 90% confidence level. Intrado PN 

Comments at 9. T-Mobile indicates that its 

threshold is 300 meters at a 90% confidence level. 

T-Mobile July 26, 2023 Ex Parte at 1. Verizon 

indicates that its threshold is 200 meters at a 90% 

confidence level. Verizon July 13, 2023 Ex Parte at 

1. 

120NENA NPRM Comments at 3 (arguing that 

‘‘location-based routing rules should apply equally 

to geodetic and civic locations known to the 

originating service provider’’). 

121Amending the Definition of Interconnected 

VoIP Service in Section 9.3 of the Commission’s 

Rules; Wireless E911 Location Accuracy 

Requirements; E911 Requirements for IP-Enabled 

Service Providers, GN Docket No. 11–117, PS 

Docket No. 07–114, WC Docket No. 05–196, Third 

Report and Order (76 FR 59916, September 28, 

2011) and Notice of Proposed Rulemaking and 

Second Further Notice of Proposed Rulemaking (76 

FR 47114, August 4, 2011), 26 FCC Rcd 10074, 

10105, para. 92 (2011). Examples of scenarios in 

which the CMRS provider would have an estimated 

civic address include a caller connecting to the 

network using a Wi-Fi access point or femtocell. 

See id. 

122Southern Linc NPRM Reply at 6 (stating that 

to the extent available location information does not 

meet the requirements for timeliness or location 

accuracy for a particular 911 call, CMRS providers 

are in the best position to determine what kind of 

location information constitutes the ‘‘best 

available’’); CTIA NPRM Comments at 4–5; Verizon 

NPRM Comments at 4 (‘‘Verizon agrees that 

network-based routing will remain necessary as a 

fallback when available location information does 

not meet the relevant accuracy and confidence/ 

uncertainty threshold. This approach serves 911 

callers’ needs as a large majority of calls using 

network-based routing will be as reliable as LBR.’’); 

DISA NPRM Comments at 2. 

123See, e.g., 47 CFR 9.16(b)(3)(ii) (stating that ‘‘an 

on-premises non-fixed device associated with a 

multi-line telephone system shall provide to the 

appropriate PSAP automated dispatchable location, 

when technically feasible; otherwise, it shall 

provide dispatchable location based on end user 

manual update, or alternative location as defined in 

§ 9.3’’). 

124 Intrado NPRM Comments at 5 (‘‘Intrado 

recommends that when the location information 

does not meet these timing/accuracy specifications, 

the proposed rules require fallback to tower-based 

routing rather than best available location 

information consistent with current CMRS 

deployments of LBR and industry standards.’’); 

NASNA NPRM Comments at 12; COPUC NPRM 

Comments at 6. 

precision.118 While no best practices 

have currently been developed, CMRS 

providers’ implementations indicate a 

practical consensus that location-based 

routing can consistently be used when 

location information meets this 

threshold. We therefore decline to 

condition compliance with these rules 

on the completion of best practices by 

ATIS. We encourage ATIS to develop 

best practices to promote optimal 

routing on CMRS providers’ networks. 

83. While we require CMRS providers 

to use location-based routing when 

available location information is within 

a 165-meter radius at a standardized 

90% confidence level, we emphasize 

that CMRS providers may also use 

location-based routing when location 

information available at time of routing 

is less precise than the accuracy 

threshold we adopt. To this extent, we 

agree with Verizon that CMRS providers 

should have flexibility to identify 

‘‘provider-optimized threshold range[s] 

to accommodate individual service 

providers’ vendor capabilities and user 

device capabilities.’’ We therefore 

provide flexibility to providers to set 

their own thresholds for use of locationbased routing at a radius exceeding 165 

meters at a 90% confidence level. While 

AT&T uses the 165-meter accuracy 

threshold, Verizon and T-Mobile have 

implemented accuracy thresholds of 200 

meters and 300 meters, respectively, 

with a standardized 90% confidence 

level.119 This formulation provides 

flexibility for all three nationwide 

CMRS providers to continue applying 

their respective thresholds for 

determining when to use location-based 

routing for 911 calls and RTT 

communications to 911. 

84. We confirm that the location 

accuracy threshold used for locationbased routing of a radius of 165 meters 

at a confidence level of at least 90% 

would apply equally to both estimated 

civic address and coordinate-based 

location. We agree with NENA that a 

CMRS provider may have access to an 

estimated civic address for a calling 

device that may be used for locationbased routing.120 Many fixed broadband 

internet access devices, particularly 

those provided to the consumer by the 

broadband service provider, are 

permanently located at a civic (street) 

address, which is known to the network 

provider.121 If a CMRS provider has 

access to either an estimated civic 

address or coordinate-based location 

that represents a horizontal location 

uncertainty level of the device within a 

radius of 165 meters at a confidence 

level of at least 90% and that location 

is available at time of routing, the CMRS 

provider must use such information to 

comply with the Commission’s locationbased routing rules. 

c. Default to Best Available Location 

Information 

85. In the notice of proposed 

rulemaking, the Commission proposed 

that when location information does not 

meet one or both thresholds for 

accuracy and timeliness under our 

rules, CMRS and covered text providers 

would be required to route wireless 911 

voice calls and texts to 911 based on the 

best location information available at 

the time the call is routed, which may 

include cell tower coordinates. We 

adopt this requirement as proposed for 

CMRS providers’ routing of wireless 911 

voice calls and RTT communications to 

911. We find that this approach allows 

flexibility for CMRS providers to 

determine the best available location 

information for routing when the 

available location information does not 

meet the thresholds for timeliness and 

accuracy. 

86. Commenters generally support a 

flexible fallback approach to routing of 

calls and texts that do not meet the 

timeliness and accuracy thresholds for 

location-based routing.122 As the 

Commission stated in the notice of 

proposed rulemaking, a requirement to 

default to best available location 

information is consistent with ATIS– 

0500039, which assumes that ‘‘the 

fallback for location-based routing 

should be cell sector routing ‘for cases 

wherein no position estimate is 

available in time to be used for 

[location-based routing] or the position 

estimates lack requisite accuracy.’ ’’ This 

approach is also consistent with current 

CMRS provider deployments of 

location-based routing, which default to 

legacy E911 routing when location does 

not meet carriers’ individually-set 

thresholds for accuracy and timely 

availability. For scenarios in which 

available location information does not 

meet the accuracy or timeliness 

thresholds, we believe that the CMRS 

provider is best suited to make the 

determination of the location 

information that is most likely to 

support accurate call routing. Defaulting 

to best available location information 

when preferred location is unavailable 

is consistent with other Commission 

rules regarding the provision of location 

information with 911 calls. In these 

rules, the Commission requires 

providers to supply highly precise 

location information when technically 

feasible but permits reliance on 

alternative location information when 

highly precise location information is 

not available.123

87. Some commenters argue that 

CMRS providers should be required to 

use tower-based routing when the 

device-based location information 

available to the network at the time of 

routing exceeds the threshold,124 or that 

the Commission should limit towerbased routing to scenarios in which ‘‘no 

other option exists.’’ We agree with 

CTIA and iCERT that location 

information that is less accurate than 

the proposed accuracy threshold but 

more accurate than cell sector, for 

example, device-based location 

information that arrives at the network 

in time for routing but exceeds the 165- 

meter threshold, could still enhance the 


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125BRETSA NPRM Reply at 10. BRETSA states 

that ‘‘[r]eference to the tower location for 

verification would simply invalidate the caller 

location in those cases in which the caller is located 

in a jurisdiction other than that in which the PSAP 

to which 9–1–1 calls received by the cell site are 

default routed. It would result in the very 

misrouting of the call LBR is being implemented to 

correct.’’ Id. at 11. 

126Most commenters who address the issue 

oppose a validation requirement. See, e.g., AT&T 

NPRM Comments at 4–5; T-Mobile NPRM 

Comments at 10; T-Mobile NPRM Reply at 4; 

Verizon NPRM Comments at 4; Verizon NPRM 

Reply at 2; ATIS NPRM Comments at 4–5; BRETSA 

NPRM Reply at i, 10–11. 

127CTIA July 3, 2023 Ex Parte at 2; Intrado NPRM 

Comments at 2, 5–6; Texas 9–1–1 Entities NPRM 

Comments at 5–6 n.21; NENA NPRM Reply at 5 

(‘‘NENA supports Intrado’s request to initiate an 

NG9–1–1 proceeding to refresh the record on NG9– 

1–1.’’); Verizon NPRM Reply at 5 (‘‘[C]oupling LBR 

with a framework for i3-based NG911 

implementation would promote more efficient 

deployment by minimizing redundant 

implementation of interim and i3 NG911-based LBR 

while also rewarding wireless providers that have 

diligently worked to support end-to-end i3-based 

NG911.’’); see also GCI July 17, 2023 Ex Parte at 1 

(‘‘[A]ddressing any new requirements for IP 

delivery of wireless calls to PSAPs as part of the 

FCC’s larger NG911 proceeding will facilitate 

consistent rules across network types and will make 

compliance with any new rules more efficient and 

effective for all service providers.’’); Alaska 

Telecom Association NPRM Comments at 8–9 (rec. 

Aug. 9, 2023) (filed in both PS Dockets 21–497 and 

18–64) (‘‘[T]he FCC should address and align any 

new requirements for IP delivery of wireless calls 

to PSAPs proposed in the LBR proceeding (PS 

Docket No. 18–64) with any IP-delivery 

requirements adopted in this NG911 proceeding.’’). 128Commenters who filed comments on this issue 

in the docket for this proceeding (PS Docket No. 

18–64) do not need to re-file their comments in PS 

Docket No. 21–479. 

129As we discuss herein, we do not require 

validation of location information used for locationbased routing. However, if providers perform any 

validation of routing location data, they should 

identify such practices as part of their certification. 

likelihood of routing the call to the 

appropriate PSAP, and the rules we 

adopt allow the use of such information 

for routing if it is the best available. 

88. We make minor modifications to 

the rule to clarify that the ‘‘best 

available location information’’ to the 

network at time of routing may take 

several forms. In the notice of proposed 

rulemaking, the proposed rule stated 

that best available location information 

‘‘may include the latitude/longitude of 

the cell tower.’’ We emphasize that the 

Commission used the latitude/longitude 

of the cell tower only as an illustrative 

example and that this language was not 

intended to limit CMRS providers to 

only using cell tower coordinates as a 

default or fallback. Southern Linc states 

that the most effective way to minimize 

misroutes is to enable CMRS providers 

to route calls based on the best location 

information available at the time of the 

call, regardless of the technology or 

solution. We agree. NENA states that the 

most appropriate geodetic location for 

each sector would be the centroid of the 

area served by each cell sector, instead 

of the coordinates of the cell tower. We 

revise the proposed rule language to 

indicate that when information of a 

device’s location does not meet either 

one or both requirements for timeliness 

and accuracy, CMRS providers must 

route the wireless 911 voice calls or 

RTT communications to 911 based on 

the best available location information, 

which may include, but is not limited 

to, device-based location information 

that does not meet the timeliness and 

accuracy requirements, the centroid of 

the cell sector that first picks up the call, 

or other location information. 

d. Validation 

89. In the notice of proposed 

rulemaking, the Commission sought 

comment on whether to require 

validation of location information for 

wireless 911 voice calls and texts to 911 

for purposes of location-based routing 

and, if so, what validation steps CMRS 

and covered text providers should be 

required to take. Some commenters 

support validation, citing concerns that 

911 calls can be spoofed or purposefully 

misrouted for swatting incidents. 

However, AT&T states that in its 

experience, invalid location under 

location-based routing is ‘‘extremely 

rare.’’ BRETSA contends that requiring 

validation would be counterproductive 

because ‘‘[v]alidating caller/device 

locations against cell-site (Phase I) 

location would appear to defeat the 

purpose of device-based LBR.’’ 125

90. We decline to implement a 

validation requirement for the location 

information used by CMRS providers for 

routing at this time, as validation 

protocols are still evolving.126 We will 

continue to monitor location 

information validation and will 

consider validation requirements for 

CMRS providers if such requirements 

become necessary. To aid in this 

monitoring, in the certification and 

reporting requirements discussed 

herein, we adopt requirements for 

CMRS to collect and report information 

on validation procedures they use with 

location-based routing. 

B. Delivery of Wireless 911 Calls and 

Texts to NG911 Networks 

91. In the notice of proposed 

rulemaking, the Commission proposed 

requiring CMRS and covered text 

providers to deliver 911 calls, texts, and 

associated routing information in IP 

format upon request of 911 authorities 

who have established the capability to 

accept NG911-compatible IP-based 911 

communications. In the subsequent 

NG911 Notice of Proposed Rulemaking, 

the Commission proposed similar 

requirements for wireline, 

interconnected VoIP, and internet-based 

TRS providers. Several commenters 

express support for addressing IP 

delivery requirements for CMRS and 

covered text providers as part of a 

consolidated NG911 proceeding.127

92. We agree that consolidating 

similar issues and aligning requirements 

for NG911 services across different 

types of originating service providers 

will result in more consistent rules and 

avoid confusion among stakeholders. 

Accordingly, we defer consideration of 

IP delivery for CMRS and covered text 

providers, including all associated 

proposals and issues raised in the notice 

of proposed rulemaking, to the NG911 

transition proceeding, PS Docket No. 

21–479. We acknowledge the comments 

in the record of this proceeding 

regarding the Commission’s proposals 

on this issue, and we will address those 

comments in the NG911 proceeding.128

C. Certification and Reporting 

Requirements 

93. Certification and Reporting 

Requirements. In the notice of proposed 

rulemaking, the Commission sought 

comment on whether it should 

implement any new data collections to 

assist in monitoring compliance with 

the proposed location-based routing 

rules. The Commission also sought 

comment on what information providers 

should include and how frequently they 

should be required to report. In 

addition, the Commission asked 

whether it should require providers to 

certify that they are in compliance with 

requirements for location-based routing. 

94. NASNA and COPUC support an 

information collection to assess 

compliance and implementation of 

location-based routing. To help the 

Commission monitor compliance with 

the location-based routing requirements 

we adopt, we adopt certain one-time 

certification and reporting requirements. 

Specifically, we require that within 

sixty days after CMRS providers’ 

respective compliance deadlines, they 

must certify that they are in compliance 

with the location-based routing 

requirements applicable to them. As 

part of the certification, CMRS providers 

must substantiate compliance by 

identifying specific network 

architecture, systems, location 

validation,129 and procedures used to 

comply with the location-based routing 

requirements. We also require CMRS 

providers on a one-time basis to collect 

and report aggregate data on the routing 

technologies used for live 911 calls in 


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130See 47 CFR 0.459. 

131CMRS providers providing service in any of 

the Test Cities or portions thereof must collect and 

report aggregate data on the location technologies 

used for live 911 calls in those areas. 47 CFR 

9.10(i)(3)(ii). Non-nationwide CMRS providers are 

required to report from alternative areas as specified 

in 47 CFR 9.10(i)(3)(ii)(D) and (E). 

132See Electronic Privacy Information Center 

(EPIC) Notice of Proposed Rulemaking Comments at 

6–7 (rec. Feb. 16, 2023) (EPIC NPRM Comments). 

The Commission’s data privacy and security 

requirements for dispatchable location and z-axis 

location information provide that prior to use of 

dispatchable location information or z-axis location 

information, respectively, to meet the location 

accuracy requirements, CMRS providers must 

certify that neither they nor any third party they 

rely on to obtain such location information will use 

the locations specified for live 911 call 

location data in § 9.10(i)(3)(ii) of the 

Commission’s rules. CMRS providers 

must collect these data for a thirty-day 

period beginning on the applicable 

compliance date. 

95. CTIA requests that we establish a 

‘‘presumption of confidentiality from 

disclosure of detailed network 

information’’ that is required to be 

included in the certifications outlined 

in the Report and Order. In support of 

its request, CTIA states that ‘‘wireless 

providers customarily treat network 

information as confidential for 

competitive and security reasons’’ and 

cites to a proceeding in which the 

Commission concluded that outage 

reports should be routinely treated as 

confidential information and are 

presumptively protected from public 

disclosure under the Freedom of 

Information Act. Based on the current 

state of the record, we decline to 

establish a presumption of 

confidentiality for the one-time 

certification and reporting requirements 

adopted in the Report and Order. CMRS 

providers may request confidential 

treatment under the Commission’s 

existing confidentiality rules 130 for 

materials submitted pursuant to these 

new requirements, specifying the 

information they wish to keep 

confidential and providing the required 

justification. We note that the 

Commission retains the right to release 

aggregated or anonymized data that 

would not reveal specific information 

for which confidential treatment has 

been sought, including doing so on its 

website, in order to facilitate 

transparency and compliance with the 

rules. In addition, nothing in this 

document or the Report and Order is 

intended to limit the authority of state 

and local 911 agencies to publish 911 

call data to the extent authorized under 

state or local law. 

96. CTIA requests that the 

Commission permit providers to submit 

certifications in the public docket 

‘‘while separately allowing providers to 

submit the required network 

information and live call data directly to 

Commission staff.’’ We direct the Public 

Safety and Homeland Security Bureau 

to issue a Public Notice prior to the 

deadline for nationwide CMRS 

providers to file compliance 

certifications and live call data. Such a 

Public Notice will include necessary 

instructions for CMRS providers to file 

certifications and reports in compliance 

with the requirements adopted. 

97. CMRS providers must file the 

required certifications and live call data 

within 60 days after the compliance 

deadlines applicable to them under the 

location-based routing rules. This means 

that for voice calls to 911, a nationwide 

CMRS provider must file its certification 

and live call data within 60 days after 

the six-month deadline for deploying 

location-based routing technology on its 

IP-based networks, and a nonnationwide CMRS provider must file its 

certification and live call within 60 days 

after the 24-month deadline for 

deploying location-based routing 

technology on its IP-based networks. In 

addition, all CMRS providers that have 

implemented the capability for RTT 

communications to 911 must file a 

certification within 60 days after the 24- 

month deadline for deploying a 

technology that supports location-based 

routing for RTT communications. We do 

not require live call data reporting for 

RTT communications to 911. 

98. Under the one-time reporting 

requirement for live 911 calls, CMRS 

providers must collect and report on (1) 

the number and percentage of wireless 

911 voice calls routed with device-based 

location information that meets the 

accuracy threshold we adopt (i.e., 

within a radius of 165 meters or less at 

a confidence level of at least 90%); (2) 

the number and percentage of wireless 

911 voice calls routed with device-based 

location information that exceeds that 

threshold (i.e., within a radius larger 

than 165 meters at a confidence level of 

90%); and (3) the number and 

percentage of wireless 911 voice calls 

routed by tower-based routing. We 

believe that this information will help 

us evaluate each CMRS provider’s 

deployment of location-based routing. 

We also encourage but do not require 

CMRS providers to include the number 

of device-based location results being 

discarded as invalid in their reports 

filed with the FCC. To minimize the 

reporting burden on CMRS providers, 

we require them to collect and report on 

911 routing methods for live 911 voice 

calls only once, only for the areas 

specified for live 911 call location data 

in § 9.10(i)(3)(ii) of the rules,131 and 

only for a thirty-day period following 

specified compliance dates. As noted 

above, we do not require similar 

reporting for RTT communications to 

911. 

99. We believe that these limited data 

collections strike an appropriate balance 

between the public safety community’s 

interest in greater transparency with 

respect to compliance and our goal of 

limiting the burden of responding to 

mandatory information collections, 

particularly for small entities. These 

limited information collections will 

promote transparency by ensuring that 

the public has a clear understanding of 

timelines for providers’ 

implementations of location-based 

routing technology and the level of 

compliance with location-based routing 

rules. Moreover, they will promote 

accountability by requiring CMRS 

providers to show steps they are taking 

to ensure that wireless 911 voice calls 

and RTT communications to 911 are 

routed to the appropriate PSAP. 

100. Recurring Reporting 

Requirements. The Commission also 

sought comment on whether it should 

adopt recurring or ongoing reporting 

requirements. NASNA and COPUC 

support requiring CMRS providers to 

disclose on a recurring basis to the FCC 

how many 911 calls are routed by 

location-based routing and how many 

are routed using legacy E911 call 

routing. NASNA and COPUC argue that 

‘‘[t]his will allow the Commission to 

determine if certain carriers are 

resorting to default routing more 

frequently than others, which may 

prompt an investigation to determine if 

those carriers are making sufficient 

efforts to fully implement LBR.’’ RWA 

opposes recurring data collection and 

reporting requirements as ‘‘extremely 

burdensome’’ for small providers, 

although it suggests that the 

Commission could request performance 

data on a voluntary basis. We believe 

that the one-time certification and 

reporting requirements we adopt will be 

sufficient for providers to demonstrate 

location-based routing implementation 

without posing an undue burden for 

providers, particularly small entities. 

Therefore, we decline to adopt ongoing 

reporting requirements. 

101. Privacy and Security. The 

Electronic Privacy Information Center 

(EPIC) expresses concern about 

potential misuse of emergency location 

data and urges the Commission to 

clarify that the privacy and security 

requirements for dispatchable location 

and z-axis location data also apply to 

location-based routing data.132 EPIC also 


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such location information or associated data for any 

non-911 purpose, except with prior express consent 

or as otherwise required by law. 47 CFR 

9.10(i)(4)(iv) and (v). The certification must state 

that CMRS providers and any third party they rely 

on to obtain such location information will 

implement measures sufficient to safeguard the 

privacy and security of such location information. 

Id. 

133EPIC NPRM Comments at 7. EPIC states that 

‘‘[t]he location data market is a multi-billion-dollar 

industry. Like many other companies that collect 

location data, carriers have sold their customers’ 

information to data brokers who have then sold 

access to anyone willing to buy—from bounty 

hunters to the government. The disclosure and sale 

of location data has serious implications for equity 

because vulnerable people are most likely to be the 

targets of surveillance.’’ Id. at 3 (footnotes omitted). 

134Under the definition we adopt, location 

information used for location-based routing may 

include, but is not limited to, device-based location 

information. 

135Wireless E911 Location Accuracy 

Requirements, PS Docket No. 07–114, Sixth Report 

and Order and Order on Reconsideration, 35 FCC 

Rcd 7752, 7777, at para. 57 (2020), 85 FR 53234 

(August 28, 2020). 

136See EPIC NPRM Comments at 5–6. The 

Commission’s privacy rules, including those 

governing the use, disclosure, and access to CPNI, 

are at 47 CFR 64.2001 through 64.2011. 

137 47 U.S.C. 222(d)(4)(A). 

138COPUC NPRM Comments at 7 (also stating 

that if a call ‘‘was routed using LBR and still was 

delivered to the wrong PSAP, that indicates the 

possibility of an error in the GIS [geographic 

information system] dataset being used by the 

CMRS provider to determine the proper destination 

for the 911 call’’). 

139AT&T NPRM Comments at 5; T-Mobile NPRM 

Comments at 8; T-Mobile NPRM Reply at 5–6; 

NENA NPRM Comments at 6 (stating that standards 

under development make such disclosure 

requirements unnecessary, but also stating that ‘‘[i]t 

is imperative that the positioning source for the 9– 

1–1 caller is provided with the call’’). 

urges the Commission to clarify the data 

use cases that fall within the scope of 

‘‘911 purposes’’ and to allow the use of 

such data only for routing calls and 

dispatch assistance. In particular, EPIC 

urges the Commission ‘‘to clarify that 

law enforcement cannot use 911 

location data for investigative leads or 

for enforcement unrelated to the 

purpose of the 911 call.’’ EPIC also asks 

the Commission to clarify that carriers 

are responsible for their third-party 

vendors’ collection, use, and disclosure 

of device-based location data.133

102. We agree that it is imperative for 

service providers to ensure the privacy 

and security of location-based routing 

information, and we adopt a rule 

clarifying that the Commission’s 

existing rules on the privacy and 

security of dispatchable location and zaxis information apply to information 

used for location-based routing. In 

particular, we require CMRS providers 

to certify that neither they nor any third 

party they rely on to obtain location 

information or associated data used for 

compliance with the location-based 

routing requirements will use such 

information or associated data for any 

non-911 purpose, except with prior 

express consent or as otherwise required 

by law. The certification also must state 

that the CMRS providers and any third 

parties they rely on to obtain location 

information or associated data used for 

compliance with the location-based 

routing requirements have implemented 

measures sufficient to safeguard the 

privacy and security of such 

information.134 These requirements 

make clear that CMRS providers who 

work with third-party vendors in the 

context of location-based routing are 

responsible for ensuring that those 

vendors take appropriate measures to 

address privacy and security 

concerns.135 The privacy and security 

certifications are due at the same time 

as the other location-based routing 

certifications (i.e., within 60 days after 

the compliance deadlines applicable to 

the CMRS providers under the locationbased routing rules). 

103. EPIC also asks the Commission to 

clarify how its privacy and security 

rules, including those governing using, 

disclosing, and permitting access to 

Customer Proprietary Network 

Information (CPNI), apply to devicebased location data.136 Section 222 of 

the Communications Act of 1934, as 

amended, requires CMRS providers, 

among others, to protect the 

confidentiality of location information 

and prohibits them from using, 

disclosing, or permitting access to 

location information without the 

customer’s express prior authorization, 

but provides an exception for the 

provision of a customer’s call location 

information to a PSAP or other 

emergency response authority in 

connection with a 911 call.137 To help 

remove uncertainty for CMRS providers, 

we clarify that the obligations that apply 

to dispatchable location data also apply 

to location information used for 

location-based routing, including 

device-based location data. 

104. We decline EPIC’s request to 

clarify the definition of ‘‘911 purposes.’’ 

We believe that the Commission’s 

existing privacy protections for 911 

location data are sufficiently clear, and 

that determining whether a particular 

use of location data is for ‘‘911 

purposes’’ is likely to be a fact-specific 

inquiry best addressed on a case-by-case 

basis as the need arises. We decline to 

address the issue of law enforcement’s 

ability to use 911 location data for 

investigative or law enforcement 

purposes, as this is an area outside the 

Commission’s regulatory authority. We 

also decline EPIC’s request to require 

CMRS and covered text providers to 

delete location data as outside the scope 

of this proceeding, as the notice of 

proposed rulemaking did not propose or 

seek comment on requirements for data 

minimization. We recognize data 

minimization as an important tool to 

protect the privacy and security of 

customers’ information, and we 

encourage providers not to retain 911 

location routing data longer than is 

necessary to fulfill the 911 purpose of 

the data or comply with applicable law. 

105. Per-Call Disclosure 

Requirements. The Commission sought 

comment on whether to require CMRS 

providers to disclose to PSAPs or state 

or local 911 authorities the routing 

methodology used for each 911 call, 

although the Commission declined to 

propose such a requirement. COPUC 

and BRETSA urge the Commission to 

require per-call disclosure. COPUC 

states that ‘‘[n]ot knowing whether the 

call was routed using LBR technology or 

default E911 methodology, the PSAP 

will have to follow up on every 

misrouted call to determine the cause of 

the misroute.’’ 138 BRETSA states that 

routing methodology information can 

allow dispatchers to assess the 

likelihood that they need to transfer the 

call and the reliability of the caller 

location information. However, TMobile and NENA argue that such a 

requirement is unnecessary.139 T-Mobile 

asserts that the positioning technology 

used to route each call is not actionable 

for PSAPs and that in a full NG911 

environment, positioning technology 

information will be available with each 

call. NENA similarly states that NG911 

system elements already ‘‘partly’’ meet 

the need for per-call information on 

routing mechanisms and that additional 

standards development is under way 

and should meet this need ‘‘in full.’’ In 

light of the forthcoming development of 

NG911 standards that will support 

disclosure of per-call routing 

methodology, we agree with T-Mobile 

and NENA that any incremental benefit 

from requiring such disclosures at this 

time would not outweigh the potential 

costs of this requirement. 

D. Additional Proposals 

106. Several commenters raised 

additional issues or proposals in 

response to the notice of proposed 

rulemaking. We discuss each of these 

issues or proposals in turn below. 

107. Role of Next Generation Core 

Services (NGCS) Providers. NENA and 

T-Mobile indicate that the proposals in 

the notice of proposed rulemaking 


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140NENA NPRM Comments at 11 (‘‘Under the 

proposal to establish an ESInet as a termination 

point for location, there may exist a gap in 

regulatory coverage. There may be a need to apply 

regulatory coverage to ESInet providers to ensure 

that calls and location are delivered through the 

ESInet all the way to the PSAP.’’); T-Mobile NPRM 

Comments at 7 (asserting that there is a gap in the 

NPRM with respect to routing obligations for calls 

delivered to an ESInet and that ‘‘[t]his raises the 

question of where the burden of compliance rests 

if a call is misrouted in this scenario’’). 

141Section 1 of the Communications Act of 1934 

as amended provides that the FCC ‘‘regulat[es] 

interstate and foreign commerce in communication 

by wire and radio so as to make [such service] 

available, so far as possible, to all the people of the 

United States, without discrimination on the basis 

of race, color, religion, national origin, or sex.’’ 47 

U.S.C. 151. 

142Notice of Proposed Rulemaking, 37 FCC Rcd 

at 15205–06, para. 59. The term ‘‘equity’’ is used 

here consistent with Executive Order 13985 as the 

consistent and systematic fair, just, and impartial 

treatment of all individuals, including individuals 

who belong to underserved communities that have 

been denied such treatment, such as Black, Latino, 

and Indigenous and Native American persons, 

Asian Americans and Pacific Islanders and other 

persons of color; members of religious minorities; 

lesbian, gay, bisexual, transgender, and queer 

(LGBTQ+) persons; persons with disabilities; 

persons who live in rural areas; and persons 

otherwise adversely affected by persistent poverty 

or inequality. See E.O. 13985, 86 FR 7009, 

Executive Order on Advancing Racial Equity and 

Support for Underserved Communities Through the 

Federal Government (Jan. 20, 2021). 

143COPUC NPRM Comments at 8; see also NENA 

NPRM Reply at 9 (concurring with NASNA’s equity 

comments on supporting location-based routing for 

text-to-911, but arguing that the Commission’s rules 

‘‘should not back the market into adopting nonstandardized technologies for a legacy platform’’ 

regarding routing obligations and 

ESInets may leave a regulatory gap with 

respect to routing functions performed 

by ESInet administrators and next 

generation core services (NGCS) 

providers.140 T-Mobile notes that once a 

carrier hands the 911 call over to the 

NGCS provider at the ESInet ingress 

point, the carrier cannot control how the 

call is routed, and the notice of 

proposed rulemaking ‘‘does not 

contemplate that the NGCS provider is 

also required to use LBR when routing 

to the appropriate PSAP.’’ T-Mobile 

urges the Commission to ensure that 

carriers do not ‘‘bear the burden of 

noncompliance’’ after the carrier routes 

the 911 call to ESInets. Because the 

Commission only considered 

requirements for CMRS and covered text 

providers in the notice of proposed 

rulemaking, we decline to consider the 

role of NGCS providers in routing at this 

time and defer to the NG911 transition 

proceeding in PS Docket No. 21–479 the 

consideration of NGCS providers’ 

responsibilities with regard to locationbased routing and any related liabilities. 

108. 2019 Wireline Forbearance 

Memorandum Opinion and Order. We 

received a comment from Mr. Ronald R. 

Fenwick urging the Commission to 

revisit and revise a 2019 Memorandum 

Opinion and Order in another 

proceeding which granted price cap 

incumbent Local Exchange Carriers 

(LECs) forbearance from legacy 

regulatory obligations. Mr. Fenwick 

asserts that the Memorandum Opinion 

and Order resulted in diminishing 

subscribers to traditional landline 

services, and that wireless customers are 

not properly apprised of the advantages 

of wireline service. We decline to revisit 

the 2019 Memorandum Opinion and 

Order, which does not deal with 

wireless services and is therefore 

outside the scope of this proceeding. 

109. Calls and Texts Originating 

Outside the United States. We received 

a comment from staff of the Defense 

Information Systems Agency (DISA) 

asking the Commission to consider 

location-based routing for 911 calls and 

texts originating outside the United 

States and its territories. This request 

raises legal and policy issues that are 

beyond the scope of this proceeding. 

110. Location-Based Routing for VoIP. 

We received a comment from DISA 

asking the Commission to apply 

location-based routing requirements to 

‘‘landline-based VoIP 9–1–1 calls 

coming from Ethernet wired end 

instruments and connecting to the 

Public Switch Telephone Network using 

Session Initiation Protocol (SIP) trunks 

from an IP–PBX.’’ We note that in the 

Next Generation 911 proceeding (PS 

Docket 21–479), the Commission 

proposed rules (NG911 Notice of 

Proposed Rulemaking) requiring 

interconnected VoIP providers to 

complete all translation necessary to 

deliver 911 calls, including associated 

location information, in the requested 

IP-based format to an ESInet or other 

designated point(s) that allow 

emergency calls to be answered. We 

defer consideration of this issue to the 

Next Generation 911 proceeding. 

E. Promoting Digital Equity and 

Inclusion 

111. As noted in the notice of 

proposed rulemaking, the Commission 

is engaged in a continuing effort to 

advance digital equity for all,141

including people of color, persons with 

disabilities, persons who live in rural or 

Tribal areas, and others who are or have 

been historically underserved, 

marginalized, or adversely affected by 

persistent poverty or inequality.142 The 

notice of proposed rulemaking invited 

comment on equity-related 

considerations and benefits, if any, that 

may be associated with the proposals 

and issues under consideration. 

Specifically, the Commission sought 

comment on how its proposals may 

promote or inhibit advances in 

diversity, equity, inclusion, and 

accessibility. 

112. Several parties submitted 

comments on these issues. NENA states 

that location-based routing should be 

deployed regardless of a jurisdiction’s 

NG911 status and that ‘‘[i]t would be 

inequitable to restrict the life-saving 

benefits of location-based routing’’ only 

to those ‘‘with the good fortune of 

having an emergency in a convenient 

location’’ with NG911 capability. As 

discussed herein, we adopt rules that 

require CMRS providers to implement 

location-based routing on their IP-based 

networks for wireless 911 voice calls 

nationwide, regardless of whether a 

particular jurisdiction has NG911 

capability. These rules will help to 

ensure that location-based routing is 

available for wireless 911 voice calls 

nationwide and regardless of the service 

provider the caller has chosen. 

113. NASNA notes that in the notice 

of proposed rulemaking, the 

Commission sought comment not just 

on equity-related considerations, but 

also ‘‘on the degree to which funding 

and operating transitional facilities 

extend the timeline and add to the cost 

incurred by state and local 911 

authorities to transition to NG911.’’ 

NASNA believes that ‘‘these two issues 

are inextricably linked,’’ and NASNA 

raises ‘‘the issues facing our members in 

providing equal access to 911 services to 

all citizens through local NG911 

systems.’’ Pointing to the NG911 Notice 

of Proposed Rulemaking comment 

record as well, NASNA urges that ‘‘the 

equity-access consideration for 911 at 

this point in time should begin at the 

network level in which 911 calls 

themselves are transported.’’ NASNA 

states, ‘‘If all those calling or texting 911 

do not have a consistent level of access 

to network functionality, we believe the 

gap in digital disparity in effective and 

reliable access to 911 across the country 

will widen all the more.’’ Because 

NASNA’s comments regarding equity 

and access are more closely related to 

the NG911 proceeding than the instant 

proceeding, we defer consideration of 

these points to the NG911 proceeding. 

114. COPUC advocates for applying 

the same implementation time frames 

for 911 texts that are being applied to 

wireless 911 voice calls (i.e., six months 

for nationwide CMRS providers and 

eighteen months for non-nationwide 

CMRS providers) as ‘‘a matter of equity 

for 911 users that rely on text-to911.’’ 143 As discussed herein, at this 


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and encouraging only voluntary deployment of 

location-based routing for ‘‘interim’’ text-to-911). 

144EPIC NPRM Comments at 1; see id. at 2, 8 

(noting that Microsoft also raised similar privacy 

and security concerns in earlier comments in the 

instant proceeding). 

145Notice of Proposed Rulemaking, 37 FCC Rcd 

at 15207–08, para. 62 & n.162 (citing U.S. 

Department of Transportation, Departmental 

Guidance on Valuation of a Statistical Life in 

Economic Analysis (Mar. 4, 2022) (later updated 

May 1, 2023), https://www.transportation.gov/ 

office-policy/transportation-policy/reviseddepartmental-guidance-on-valuation-of-astatistical-life-in-economic-analysis). 

146Notice of Proposed Rulemaking, 37 FCC Rcd 

at 15207–08, para. 62 (stating that the estimate does 

not include ‘‘the value of reduced human suffering 

and property destruction occurring due to a delayed 

arrival of first responders’’ or ‘‘the benefits of 

location-based routing for text messages’’). 

147See U.S. Department of Transportation, 

Departmental Guidance on Valuation of a Statistical 

Life in Economic Analysis (effective May 1, 2023), 

https://www.transportation.gov/office-policy/ 

transportation-policy/revised-departmentalguidance-on-valuation-of-a-statistical-life-ineconomic-analysis. 

148Respondents reported a combined total of 

824,609 texts to 911 in 2022. Fifteenth Annual 911 

Fee Report at 12–13, para. 14. 

149Notice of Proposed Rulemaking, 37 FCC Rcd 

at 15206–07, para. 61 n.161. NENA estimates that 

80% or more of the total calls to 911 annually are 

from wireless devices. NENA, 9–1–1 Statistics, 

https://www.nena.org/page/911Statistics (last 

visited Jan. 17, 2024). According to the National 

Association of State Emergency Medical Services 

Officials (NASEMSO), local Emergency Medical 

Services (EMS) agencies respond to nearly 28.5 

million 911 dispatches each year. NASEMSO (Laura 

French), National Association of State EMS 

Officials releases stats on local agencies, 911 Calls 

(Apr. 10, 2020), https://www.ems1.com/ambulanceservice/articles/national-association-of-state-emsofficials-releases-stats-on-local-agencies-911-callsLPQTHJrK2oIpxuR1/. Assuming that 80% of these 

calls are from wireless devices yields an estimate 

of 22.8 million wireless calls for 911 dispatch 

annually. The Commission estimated that 12% of 

the wireless calls for dispatch (or 2,736,000 calls) 

would be misrouted. Notice of Proposed 

Rulemaking, 37 FCC Rcd at 15206–07, para. 61 

n.161 (citing ATIS–0500039 at 4). The Commission 

also estimated that location-based routing with a 

horizontal uncertainty value of 300 meters would 

resolve approximately 50% of these misroutes. Id. 

(citing ATIS–0500039 at 13). Accordingly, the 

Commission estimated that 1,368,000 calls would 

avoid the need for a transfer due to a misroute, 

reducing the response time for these calls by one 

minute. Id. 

150The mean wage for Public Safety 

Telecommunicators in May 2022 was $23.74 per 

hour. U.S. Bureau of Labor Statistics, Occupational 

Employment and Wages, May 2022, 43–5031 Public 

Safety Telecommunicators (Apr. 25, 2023), https:// 

www.bls.gov/oes/current/oes435031.htm. The 

average hourly private wage increased by 5.5% 

according to the Bureau of Labor Statistics between 

May 2022 and August 2023, so to correct for 

inflation we increase the wage estimate by 5.5% to 

$25.04 per hour. Federal Reserve Bank of St. Louis, 

Average Hourly Earnings of All Employees, Total 

Private (CES0500000003), https://fred.stlouisfed.

org/series/CES0500000003 (last visited Jan. 17, 

2024) (Inflation Adjustment). 

151To account for benefits, we mark up wages by 

45%, which results in total hourly compensation of 

$25.04 × 145% = $36.31. According to the Bureau 

of Labor Statistics, as of June 2023, civilian wages 

and salaries averaged $29.86/hour and benefits 

averaged $13.39/hour. Total compensation therefore 

averaged $29.86 + $13.39, rounded to $43.26. See 

Press Release, Bureau of Labor Statistics, Employer 

Costs for Employee Compensation—June 2023 

(Sept. 12, 2023), https://www.bls.gov/news.release/ 

pdf/ecec.pdf. Using these figures, benefits 

constitute a markup of $13.39/$29.86 ∼ 45%. 

152PSAPs would realize an annual savings benefit 

of 1,368,000 calls × 1 minute (0.0166 hours) × 

$36.31, or over $828,000 per year. Using NENA’s 

estimate, PSAPs would realize a savings benefit of 

200,000 hours × $36.31, or approximately $7.3 

million per year. 

time we decline to require locationbased routing for text-to-911 services 

other than RTT communications to 911 

in the absence of technical standards for 

location-based routing for SMS. 

However, we reiterate our commitment 

to monitoring the development of 

standards, products, and other advances 

affecting location-based routing for SMS 

text-to-911. 

115. EPIC states that government 

entities, carriers, and others have 

misused location data to target 

individuals and groups, and says that 

‘‘the lack of clear privacy and security 

safeguards would have a 

disproportionately negative impact on 

certain vulnerable groups.’’ 144 As 

discussed herein and consistent with 

certain of EPIC’s requests, we adopt a 

requirement applying the Commission’s 

existing rules on the privacy and 

security of dispatchable location and zaxis information to location-based 

routing information. 

116. In sum, we acknowledge the 

importance of the continuing effort to 

advance digital equity for all. We 

believe that the rules we adopt, 

requiring CMRS providers to implement 

location-based routing on their IP-based 

networks for wireless 911 voice calls 

nationwide and requiring CMRS 

providers to implement location-based 

routing where they deploy RTT 

capabilities, will help to advance those 

goals. 

F. Summary of Benefits and Costs for 

Location-Based Routing 

117. As we discuss below, the 

implementation of location-based 

routing has potential annual benefits of 

over $173 billion in terms of reduced 

mortality and reduced call transfer 

burdens to PSAPs. We determine that 

the rules we adopt, which will affect 

CMRS providers, will result in an 

industry-wide compliance cost of $215 

million. 

1. Benefits of Location-Based Routing 

118. We believe that the 

Commission’s benefit assessment from 

the notice of proposed rulemaking 

remains valid. The Commission 

estimated that implementation of 

location-based routing would save 

13,837 lives annually. While the 

Commission did not attempt to place a 

value on human life, it relied on the 

U.S. Department of Transportation’s 

(DOT) valuation of a statistical life 

(VSL) of $11.8 million from base year 

2021.145 The Commission estimated that 

the benefit of reduced mortality would 

be 13,837 × $11.8 million or 

approximately $163 billion, but stated 

that this estimate was conservative.146

We received no comments on the 

estimated reduced mortality benefit. 

Using the latest VSL of $12.5 million for 

base year 2022,147 our new estimate of 

reduced mortality benefit is 

approximately $173 billion for wireless 

voice calls to 911. At this time, we have 

no data on the number of RTT 

communications to 911 to estimate a 

benefit from this service,148 but we 

anticipate that as RTT usage becomes 

more widespread, significant reduced 

mortality benefits will accrue. 

119. The Commission sought 

specificity on the time and cost savings 

to PSAPs and state and local 911 

authorities under the proposed rules. 

While we received no specific figures in 

the record, BRETSA agrees that 

misrouting of 911 calls ties up resources 

at the PSAP to which the call was 

misrouted and delays receipt of the call 

at the PSAP that can dispatch first 

responders, while T-Mobile states that 

call transfers can delay emergency 

response and result in the loss of vital 

incident information, including caller 

location. The Commission estimated 

that with implementation of locationbased routing, ‘‘1,368,000 calls would 

avoid the need for a transfer due to a 

misroute, reducing the response time for 

these calls by one minute.’’ 149 This 

would result in a time savings of 22,800 

hours annually for PSAPs, although 

NENA estimates that call transfers 

consume over 200,000 hours per year of 

excess 911 professional labor. We 

estimate the mean wage of 911 call 

operators to be $25.04 per hour,150

which leads to an estimated total labor 

cost of $36.31 per hour after accounting 

for benefits.151 We estimate that PSAPs 

would realize an annual savings benefit 

range of approximately $0.8 million to 

$74.3 million per year for wireless 911 

voice calls.152 We do not have sufficient 

data to estimate such a benefit for RTT, 

though we similarly anticipate that time 

and cost savings benefits for PSAPs will 

accrue for RTT as usage grows. 

2. Costs of Implementation 

120. In the notice of proposed 

rulemaking, the Commission provided 

separate cost estimates for materials and 

labor. The Commission sought comment 


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153For example, CCA states that location-based 

routing implementation will be economically and 

practically infeasible in the proposed eighteenmonth timeline for non-nationwide carriers, noting 

that a nationwide carrier took four years. CCA 

NPRM Comments at 2. 

154Notice of Proposed Rulemaking, 37 FCC Rcd 

at 15210–11, para. 71. The Commission assumed no 

material costs for AT&T because it has already 

deployed location-based routing to its network. Id. 

at 15210, para. 71. The Commission stated (at the 

time of the notice of proposed rulemaking) that it 

is unclear the extent to which Verizon plans to 

implement location-based routing, and did not 

estimate Verizon’s material costs. Id. at 15210–11, 

para. 71. The Commission found that T-Mobile has 

yet to implement location-based routing to 4,896 

PSAPs, while non-nationwide CMRS providers 

collectively must upgrade 5,728 PSAPs, with any 

PSAP receiving service from usually one nonnationwide CMRS provider along with the 

nationwide CMRS providers. Id. at 15211, para. 71. 

The Commission found that T-Mobile and nonnationwide CMRS providers need to implement 

location-based routing for 10,624 PSAPs (4,896 + 

5,728), at $10,000 per PSAP, for a cost of 

approximately $106 million. Id. 

155 Intrado NPRM Comments at 3. NENA defines 

a GMLC as ‘‘the point of interface between the GSM 

[Global Standard for Mobile Communications] 

wireless network and the Emergency Services 

Network. The GMLC retrieves, forwards, stores and 

controls position data associated with wireless 

callers. This includes the processing of location 

requests and updates (rebids).’’ NENA, GMLC/MLC 

(Gateway Mobile Location Center) (Sept. 13, 2021), 

https://kb.nena.org/wiki/GMLC/MLC_(Gateway_

Mobile_Location_Center.) 

156See Notice of Proposed Rulemaking, 37 FCC 

Rcd at 15211, para. 71 (citing FCC, Mobile 

Deployment Form 477 Data (Jul. 29, 2022), https:// 

www.fcc.gov/mobile-deployment-form-477-data, 

and stating that ‘‘[s]taff analysis of Form 477 data 

suggests that when that when there is a fourth nonnationwide wireless provider in any particular 

location, it is usually the only one’’). 

157We count 3,561 PSAPs remaining for TMobile, 5,057 PSAPs remaining for Verizon, and 

5,748 PSAPs for the CMRS providers that have not 

yet begun to implement location-based routing. 

on, inter alia, hardware, software, 

services, GIS, and testing; provider costs 

and timelines necessary to work with 

OS-based location providers; costs for 

providers to implement the required 

software, hardware, and service 

upgrades to comply with proposed 

rules; and how many work-hours and 

what kind of workers would be 

required; and planned or expended 

costs by providers that have 

implemented or plan to implement 

location-based routing. RWA and 

BRETSA state that non-nationwide and 

smaller carriers have not determined 

actual costs. We did not receive specific 

cost information to better inform the 

Commission’s cost assessments. 

Commenters provided information 

about network elements, tasks, and 

burdens that would factor into costs; 

however, commenters generally 

discussed such factors in the context of 

seeking more time to comply rather than 

cost aspects.153 RWA calls for additional 

time and Federal funding to support 

carrier implementation of locationbased routing and alleges that RWA 

members will not be able to comply 

with an unfunded mandate. As 

discussed herein, we are increasing the 

timelines for non-nationwide CMRS 

providers to implement location-based 

routing for wireless 911 voice calls and 

RTT communications, and deferring 

consideration of location-based routing 

requirements for texts to 911 and 

requirements to deliver 911 calls and 

texts in IP-based format. 

121. Material Costs. The Commission 

tentatively concluded that CMRS 

providers implement location-based 

routing at the PSAP level, while CMRS 

providers incur material costs on a perPSAP basis. The Commission estimated 

that the average material cost of 

software features or component 

upgrades for each CMRS provider 

would be $10,000 per PSAP as an upper 

bound, with an ‘‘implied material cost 

upper bound [of] approximately $106 

million.’’ 154 We received no comments 

to inform the Commission’s material 

cost estimate for CMRS providers to 

deploy location-based routing to PSAPs 

they serve. However, commenters 

identified core network elements 

necessary to implement location-based 

routing. Intrado states that carriers will 

need to implement geospatial routing 

capable Gateway Mobile Location 

Centers (GMLCs) so that routing 

decisions will occur within their 

networks.155 CCA states that 

‘‘[i]ncorporating location-based routing 

into the wireless ecosystem . . . 

requires a carefully orchestrated series 

of changes that affects the wireless 

carriers’ device inventory, transport 

networks, and several aspects of the 

core network systems. These potentially 

include access and mobility 

management, data authentication, 

geospatial data repository functions, 

session management, and network 

security.’’ CCA further states that 

carriers will need to ‘‘implement the 

array of device upgrades and nonstandard, proprietary network solutions 

needed for location-based routing.’’ 

RWA describes hardware and software 

modifications needed to implement 

location-based routing as a ‘‘massive 

expense,’’ and notes that member 

budgets for capital expenses are 

‘‘already pared close to the bone.’’ 

122. We agree with commenters that 

providers have certain material costs 

associated with the network core that 

are not necessarily dependent on the 

number of PSAPs they serve. We clarify, 

however, that the material costs that we 

calculated on a per-PSAP basis in the 

notice of proposed rulemaking also 

include other costs that are not 

necessarily incurred at the PSAP. We 

agree that implementation costs of 

upgrading equipment or software can, 

for instance, involve changes to the 

network core. We also note that such 

costs vary with the size of the network 

that remains to be converted to locationbased routing, especially if any 

equipment needs to be updated. We 

therefore chose the per-PSAP basis 

because we find it a convenient proxy 

of remaining network area. T-Mobile 

and Verizon report partial 

implementation of location-based 

routing based on the number of PSAPs. 

For providers with no known 

implementation, the number of their 

covered PSAPs serves as a proxy for the 

size of their entire network. We 

therefore continue to use the per-PSAP 

basis as a proxy for network size in our 

current material costs calculations. We 

note, additionally, that even if the perPSAP cost that we use below were to 

double, the aggregate expected costs of 

our rules would fall well below the 

expected benefits. 

123. The latest NENA data indicate 

that 5,748 PSAPs operate in the United 

States. AT&T has already deployed 

location-based routing nationwide, so 

our rules impose no additional material 

costs for AT&T. The Commission did 

not provide an estimate of T-Mobile’s 

material costs in the notice of proposed 

rulemaking. As of December 2023, TMobile states that it has fully 

implemented location-based routing for 

1,591 PSAPs, with an additional 596 

PSAPs in progress. Thus, T-Mobile must 

implement location-based routing to 

3,561 remaining PSAPs. The 

Commission did not provide an estimate 

of Verizon’s material costs in the notice 

of proposed rulemaking, but Verizon 

states that it has ‘‘fully implemented 

LBR for 414 PSAPs; implementation is 

in progress for an additional 277 

PSAPs.’’ Thus, the rules would impose 

no additional material costs for existing 

and planned deployments to Verizon for 

691 PSAPs, which leaves 5,057 PSAPs 

remaining for Verizon to implement 

location-based routing. The remaining 

CMRS providers collectively must 

upgrade the full national set of 5,748 

PSAPs, assuming no more than one 

remaining CMRS provider serving a 

particular PSAP.156 Using the 

Commission’s $10,000 per PSAP upper 

bound in the notice of proposed 

rulemaking, we estimate that CMRS 

providers collectively need to deploy 

location-based routing to a total of 

14,366 PSAPs,157 resulting in the 


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158Notice of Proposed Rulemaking, 37 FCC Rcd 

at 15211–12, para. 72 (estimating that the labor cost 

of employing software workers would be $35.25 per 

hour; that the upper bound of the time to 

implement the upgrades with trials is 6 months (26 

weeks), and workers have a forty hour work week, 

or 1,040 hours per worker; that ten simultaneous 

workers at a time on average is a generous upper 

bound, resulting in 10,400 labor hours per CMRS 

provider; and that the labor cost per CMRS provider 

is $366,600). 

159CCA NPRM Reply at 5. The planning costs 

CCA cites include ‘‘identifying acceptance of the 

technical implementation.’’ CCA NPRM Comments 

at 11. 

160Notice of Proposed Rulemaking, 37 FCC Rcd 

at 15211–12, para. 72 (estimating that the labor cost 

of employing software workers would be $35.25 per 

hour; that the upper bound of the time to 

implement the upgrades with trials is 6 months (26 

weeks), and workers have a forty hour work week, 

or 1,040 hours per worker; that ten simultaneous 

workers at a time on average is a generous upper 

bound, resulting in 10,400 labor hours per CMRS 

provider; and that the labor cost per CMRS provider 

is $366,600). 

161The Bureau of Labor Statistics considers the 

title ‘‘computer network architect’’ to be 

synonymous with ‘‘network engineer.’’ U.S. Bureau 

of Labor Statistics, Computer Network Architects: 

What Computer Network Architects Do (Sept. 12, 

2023), https://www.bls.gov/ooh/computer-andinformation-technology/computer-networkarchitects.htm#tab-2. To approximate the wages of 

senior network engineers, we use the 75th 

percentile of the hourly wage of computer network 

architects in May 2022, $77.06 per hour. U.S. 

Bureau of Labor Statistics, Occupational 

Employment and Wages, May 2022, 15–1241 

Computer Network Architects (Apr. 25, 2023), 

https://www.bls.gov/oes/current/oes151241.htm. 

After adjusting for wage inflation to August 2023, 

the wage increases to $81.29 per hour. See Inflation 

Adjustment. 

162To the extent that T-Mobile and Verizon have 

already begun implementing location-based routing, 

this cost may be an overestimate. 

163 Intrado NPRM Comments at 3 (suggesting 

carriers and the PSAPs should develop GIS data); 

BRETSA NPRM Reply at ii (suggesting state and/or 

local 911 authorities should develop GIS data); TMobile NPRM Comments at 6 (suggesting that 

PSAPs should provide shapefiles, though some 

PSAPs may not want to provide shapefiles because 

they consider such information confidential); see 

also CCOA NPRM Reply at 3; CTIA NPRM Reply 

Continued 

implied material cost of approximately 

$143.7 million. 

124. Labor Costs. The Commission 

estimated that the labor cost per CMRS 

provider is $366,600.158 The 

Commission explicitly mentioned the 

tasks of installing equipment and 

running trials as part of this labor. 

Commenters described other tasks such 

as internal planning, outreach, and 

testing. Since these tasks do not involve 

materials but rather involve work 

burdens, we categorize them as labor 

costs for the purpose of this analysis. 

125. Labor Costs (i): Internal Planning. 

CCA described CMRS providers’ 

internal planning tasks prior to 

implementation of location-based 

routing, which we categorize under 

labor. CCA states that carriers will need 

to vet and select potentially appropriate 

technical location-based routing 

solutions, budget for related required 

procurements, and make related plans 

to allocate and prioritize necessary 

resources to the projects.159 CCA states 

that ‘‘[t]he proposed rule would require 

carriers with IP-based networks to make 

major strategic decisions for their 

wireless networks’’ and ‘‘stand up 

project teams [comprised] of senior 

engineers and business leaders with 

specialized experience in network 

operations to assess the needs of the 

marketplace and review the state of 

technology development globally, 

nationally, and with respect to their 

individual network technologies.’’ CCA 

states that carriers will need to make ‘‘a 

candid assessment of existing network 

resources, the purposeful allocation of 

limited technical and business 

resources, and a successful matching of 

technology within the market to the 

unique features of that carrier’s network 

systems and status within the product 

evolution lifecycle’’ and conduct 

‘‘intensive’’ decision making. 

126. Labor Costs (ii): Outreach. Next, 

CCA described providers’ outreach 

tasks, such as collaboration with 

network and handset vendors; and work 

with device makers, technology 

vendors, and software service providers. 

However, CCA notes that nonnationwide CMRS providers face 

challenges attracting attention and 

assistance from global and national 

vendors who are more responsive to 

larger clients. 

127. Labor Costs (iii): Deployment. 

Commenters provided few details of 

labor tasks associated with deployment, 

including equipment and device 

installation and upgrades. 

128. Labor Costs (iv): Testing. 

Commenters described CMRS providers’ 

testing tasks involved with locationbased routing implementation. RWA 

states that providers will need to ‘‘test, 

modify, [and] perfect’’ location-based 

routing solutions. CCA states that AT&T 

performed extensive lab testing, 

performance testing, trials at PSAPs, 

evaluation of results with its vendor 

Intrado, and additional PSAP testing. 

CCA states that AT&T ‘‘confirm[ed] the 

metrics, obtain[ed] feedback from the 

PSAPs, and implement[ed] several 

proprietary changes.’’ 

129. While the notice of proposed 

rulemaking explicitly mentioned the 

tasks of installing equipment and 

running trials as part of its labor 

calculation, the estimate was not meant 

to be solely inclusive of all tasks. 

According to Commission staff 

experience with typical network 

upgrades, team members will often 

work on tasks from multiple of the 

above categories of internal planning, 

outreach, deployment, and testing. The 

notice of proposed rulemaking 

calculation assumes a large team of ten 

workers over a period of six months to 

account for the various phases of labor 

and shifting tasks amongst workers. 

130. Absent more specific data in the 

record on each task category, we rely on 

the Commission’s labor cost estimation 

methodology per CMRS provider.160 To 

better reflect the wide array of complex 

tasks, including internal network 

planning, that would need to be 

undertaken by highly skilled and senior 

staff, we will assume a higher wage for 

the workers than that assumed in the 

notice of proposed rulemaking because 

some of the tasks involved will have to 

be undertaken by senior staff. To the 

extent that less senior staff would be 

necessary to complete any of these 

tasks, we view the wage that we use as 

conservatively high. Using the Bureau of 

Labor Statistics 75th percentile wage for 

network engineers, we assume worker 

compensation to be $81.29 per hour.161

Marking up hourly compensation by 

45% to account for benefits results in a 

total hourly compensation estimate of 

$117.87. Assuming that work is 

completed over 26 work-weeks of five, 

8 work-hour days, and a team of 10, the 

aggregate upper bound of work-hours 

would be 10,400 and the total cost of 

those work-hours would be $1,225,853. 

While non-nationwide CMRS providers 

will have 24 months rather than six to 

implement location-based routing, 

smaller CMRS providers have 

constraints on the number of staff they 

can assign to any one project. In 

addition, while non-nationwide CMRS 

providers may take longer to implement 

location-based routing, assigning the 

same amount of work-time as 

nationwide CMRS providers represents 

both the spreading out of tasks over a 

longer period and an overestimate since 

non-nationwide CMRS providers have 

much smaller networks. Given that 

AT&T has already implemented 

location-based routing, we estimate the 

labor cost associated with 

implementation for the networks for the 

56 remaining providers, plus T-Mobile 

and Verizon, to be $71.1 million (≈ 

$1,225,853 × 58 providers = 

$71,099,474).162

131. In addition to network costs, 

several commenters indicate that public 

safety-grade GIS data or shapefiles that 

precisely define PSAP boundaries 

should be developed or provided, 

though they differ on which parties 

should be responsible.163 We agree with 


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at 3, 6–7 (agreeing with T-Mobile regarding the 

need for accurate shapefiles of PSAP boundaries). 

164See Office of Information and Regulatory 

Affairs, Office of Management and Budget, 

Executive Office of the President, 2022 Study Area 

Boundary Data Reporting in Esri Shapefile Format, 

DA 12–1777 and DA 13–282, Supporting 

Statement—OMB Control No. 3060–1181, at 5, para. 

12 (Feb. 15, 2022), https://www.reginfo.gov/public/ 

do/PRAViewDocument?ref_nbr=202202-3060-009; 

see also Wireless Emergency Alerts; Amendments to 

Part 11 of the Commission’s Rules Regarding the 

Emergency Alert System, PS Docket Nos. 15–91 and 

15–94, Third Report and Order, FCC 23–88, at 37, 

para. 66 (Oct. 20, 2023). 

165The mean hourly wage for data scientists in 

the telecommunications industry in May 2022 is 

$57.29. U.S. Bureau of Labor Statistics, May 2022 

National Industry-Specific Occupational 

Employment and Wage Estimates NAICS 517000— 

Telecommunications (Apr. 25, 2023), https://

www.bls.gov/oes/current/naics4_517000.htm. After 

adjusting for wage inflation to August 2023, the 

wage increases to $60.44 per hour. See Inflation 

Adjustment. 

166See 5 U.S.C. 604. The RFA, 5 U.S.C. 601–612. 

The RFA was amended by the Small Business 

Regulatory Enforcement Fairness Act of 1996 

(SBREFA), Public Law 104–121, Title II, 110 Stat. 

857 (1996). 

167 5 U.S.C. 605(b). 

168 44 U.S.C. 3507(d). 

169Public Law 107–198, 116 Stat. 729 (2002) 

(codified at 44 U.S.C. 3506(c)(4)). 

NENA that it is the responsibility of 

providers to maintain their own 

jurisdictional maps. Accordingly, we 

assign the cost of maps to the providers. 

We anticipate that map costs will 

largely be labor to update already 

existing maps. To come up with a cost 

ceiling, we assume that every provider 

will need to update its maps, even 

though many providers likely have upto-date maps. We anticipate that 

updating the map will only entail labor 

costs for mapping specialists to update 

maps. In the Supporting Document of 

Study Area Boundary Data Reporting in 

Esri Shapefile Format, the Office of 

Information and Regulatory Affairs 

estimates that it takes an average of 26 

hours for a data scientist to modify a 

shapefile.164 We believe that 26 hours 

would be an upper bound of the time 

required for a party to update its maps. 

Given that the average wage rate is 

$60.44/hour for data scientists in the 

telecommunications industry,165 with a 

45% markup for benefits, we arrive at 

$87.63 as the hourly compensation rate 

for a data scientist. We estimate an 

upper bound for the cost of map 

updating to be approximately $134,000 

(≈ $87.63 per hour × 26 hours × 59 

providers = $134,424.42). 

132. In addition, the one-time 

certification of compliance with our 

requirements together with the 

submission of data on call percentages 

by routing methods will impose a onetime cost on CMRS providers. As this 

required information should be 

available to each provider internally, we 

anticipate work to compile this 

information to take no longer than a 

week of five business days. We believe 

that one network engineer would be 

sufficient to complete this task in this 

time frame, resulting in a total provider 

cost of 40 work-hours. Assuming the 

same hourly labor cost of network 

engineers as in the previous cost 

estimate for network implementation, 

the total cost of reporting is $280,000 (≈ 

$117.87 per hour × 40 hours × 59 

providers = $278,173.20). 

133. The Commission sought 

comment on costs to state and local 911 

authorities. Intrado and APCO state that 

PSAPs will not need to make changes to 

their networks or call handling systems. 

We agree. Likewise, because we find 

that providers must maintain their own 

jurisdictional maps, we do not recognize 

any costs for state and local 911 

authorities and PSAPs. 

134. Because we are adopting 

location-based routing requirements for 

RTT, we also consider the costs for 

CMRS providers. Given that CMRS 

providers process and route RTT 

communications similarly to voice calls, 

we assume that CMRS providers’ 

material and labor costs to deploy 

location-based routing for RTT are 

included in our cost estimates above. As 

part of this analysis, we note that as of 

the release date of the Report and Order, 

we are aware of only a small number of 

PSAPs that are receiving RTT 

communications. 

135. In sum, we estimate upper 

bounds of the costs that CMRS 

providers will bear to be material costs 

of $143.7 million, network 

implementation costs of $71.1 million, 

GIS costs of $134,000, and certification 

costs of $280,000. Altogether, the upper 

bound of costs is approximately $215 

million. However, we underscore that 

this cost is far outweighed by the 

benefits of over $173 billion in terms of 

reduced mortality and call transfer time 

eliminated. 

II. Procedural Matters 

136. Regulatory Flexibility Act. The 

Regulatory Flexibility Act of 1980, as 

amended (RFA),166 requires that an 

agency prepare a regulatory flexibility 

analysis for notice and comment 

rulemakings, unless the agency certifies 

that ‘‘the rule will not, if promulgated, 

have a significant economic impact on 

a substantial number of small 

entities.’’ 167 Accordingly, we have 

prepared a Final Regulatory Flexibility 

Analysis (FRFA) concerning the 

possible impact of the rule changes 

contained in this document and the 

Report and Order on small entities. The 

FRFA is set forth below. 

137. Paperwork Reduction Act of 1995 

Analysis. This document contains new 

information collection requirements 

subject to the Paperwork Reduction Act 

of 1995 (PRA), Public Law 104–13. It 

will be submitted to the Office of 

Management and Budget (OMB) for 

review under section 3507(d) of the 

PRA.168 OMB, the general public, and 

other Federal agencies will be invited to 

comment on the new information 

collection requirements contained in 

this proceeding. In addition, we note 

that, pursuant to the Small Business 

Paperwork Relief Act of 2002,169 we 

previously sought, but did not receive, 

specific comment on how the 

Commission might further reduce the 

information collection burden for small 

business concerns with fewer than 25 

employees. The Commission does not 

believe that the new information 

collection requirements in § 9.10(s)(4) 

and (5) will be unduly burdensome on 

small businesses. We describe impacts 

that might affect small businesses, 

which includes most businesses with 

fewer than 25 employees, in the FRFA 

below. 

III. Final Regulatory Flexibility 

Analysis 

138. As required by the Regulatory 

Flexibility Act of 1980, as amended 

(RFA), an Initial Regulatory Flexibility 

Analysis (IRFA) was incorporated in the 

NPRM adopted in December 2022. The 

Commission sought written public 

comment on the proposals in the NPRM, 

including comments on the IRFA. No 

comments were filed addressing the 

IRFA. This Final Regulatory Flexibility 

Analysis (FRFA) conforms to the RFA. 

A. Need for, and Objectives of, the Final 

Rules 

139. Technical limitations of legacy 

Enhanced 911 (E911) routing can result 

in a Commercial Mobile Radio Service 

(CMRS) provider routing a wireless 911 

call to a Public Safety Answering Point 

(PSAP) other than the one designated by 

the relevant state or local 911 authority 

to receive calls from the actual location 

of the caller. Misroutes can occur for 

several reasons, including when more 

than one PSAP is within the coverage 

area of a cell site or sector. Such legacy 

tower-based routing results in 

approximately 12% of wireless 911 calls 

arriving at the incorrect PSAP for the 

caller’s location. When a 911 call is 

misrouted, the answering 

telecommunicator must transfer the call 

to the PSAP that has jurisdiction to 


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dispatch aid to the 911 caller’s location, 

resulting in confusion and an estimated 

delay of a minute or more in dispatch 

and response. This delay can have 

deadly consequences. In addition, 

misroutes consume time and resources 

for both the transferring PSAP and the 

receiving PSAP. One national public 

safety organization estimates that these 

types of call transfers consume over 

200,000 hours per year of excess 911 

professional labor. 

140. In the Report and Order, the 

Commission adopted rules and 

procedures to require CMRS providers 

to implement location-based routing 

(LBR) for wireless 911 voice calls and 

real-time text (RTT) communications to 

911 nationwide. With location-based 

routing as implemented under the 

Commission’s rules, CMRS providers 

will use precise location information to 

route wireless 911 voice calls and RTT 

communications to 911 to the 

appropriate public safety answering 

point. For the millions of individuals 

seeking emergency assistance each year 

by wireless 911 voice call or RTT 

communication to 911, improving 

routing for these services will reduce 

emergency response time and save lives. 

141. To facilitate the implementation 

of location-based routing for wireless 

911 voice calls and RTT 

communications to 911, the 

Commission took the following actions: 

• The Commission required CMRS 

providers to deploy location-based 

routing technology for wireless 911 

voice calls and RTT communications to 

911 on their internet Protocol (IP)-based 

networks (i.e., 4G LTE, 5G, and 

subsequent generations of IP-based 

networks). The Commission also 

required CMRS providers to use 

location-based routing to route wireless 

911 voice calls and RTT 

communications to 911 originating on 

their IP-based networks when location 

information meets certain thresholds for 

accuracy and timeliness. 

• The Commission required CMRS 

providers to use location-based routing 

for wireless 911 voice calls and RTT 

communications to 911 when caller 

location information available to the 

CMRS provider’s network at time of 

routing is ascertainable within a radius 

of 165 meters at a confidence level of at 

least 90%. In the absence of these 

conditions, CMRS providers must use 

alternative routing methods based on 

‘‘best available’’ location information, 

which may include but is not limited to 

device-based or tower-based location 

information. 

• The Commission adopted the 

proposed six-month timeline for 

nationwide CMRS providers to 

implement location-based routing for 

wireless 911 voice calls and provided 

twenty-four months for implementation 

by non-nationwide CMRS providers. In 

addition, the Commission provided 24 

months for all CMRS providers to 

implement location-based routing for 

RTT communications to 911. 

• The Commission required CMRS 

providers within 60 days of the 

applicable compliance deadlines to 

certify and submit evidence of 

compliance with location-based routing 

requirements and to certify the privacy 

of location information used for 

location-based routing. At that time, 

CMRS providers also must submit onetime live call data reporting specifying 

routing methodologies for calls in live 

call areas. 

• The Commission deferred 

consideration of proposals in the NPRM 

to require CMRS providers and covered 

text providers to implement locationbased routing for Short Message Service 

(SMS) texts to 911. 

• The Commission deferred 

consideration of proposals and issues 

raised in the NPRM concerning IPformatted delivery of wireless 911 voice 

calls, texts, and associated routing 

information, for consideration in the 

Commission’s pending Next Generation 

911 (NG911) Transition docket (PS 

Docket No. 21–479, Facilitating 

Implementation of Next Generation 911 

Services). 

B. Summary of Significant Issues Raised 

by Public Comments in Response to the 

IRFA 

142. There were no comments filed 

that specifically addressed the proposed 

rules and policies presented in the 

IRFA. 

C. Response to Comments by the Chief 

Counsel for Advocacy of the Small 

Business Administration 

143. Pursuant to the Small Business 

Jobs Act of 2010, which amended the 

RFA, the Commission is required to 

respond to any comments filed by the 

Chief Counsel for Advocacy of the Small 

Business Administration (SBA), and to 

provide a detailed statement of any 

change made to the proposed rules as a 

result of those comments. The Chief 

Counsel did not file any comments in 

response to the proposed rules in this 

proceeding. 

D. Description and Estimate of the 

Number of Small Entities to Which the 

Rules Will Apply 

144. The RFA directs agencies to 

provide a description of and, where 

feasible, an estimate of the number of 

small entities that may be affected by 

the rules adopted. The RFA generally 

defines the term ‘‘small entity’’ as 

having the same meaning as the terms 

‘‘small business,’’ ‘‘small organization,’’ 

and ‘‘small governmental jurisdiction.’’ 

In addition, the term ‘‘small business’’ 

has the same meaning as the term 

‘‘small business concern’’ under the 

Small Business Act.’’ A ‘‘small business 

concern’’ is one which: (1) is 

independently owned and operated; (2) 

is not dominant in its field of operation; 

and (3) satisfies any additional criteria 

established by the SBA. 

145. Small Businesses, Small 

Organizations, Small Governmental 

Jurisdictions. Our actions, over time, 

may affect small entities that are not 

easily categorized at present. We 

therefore describe, at the outset, three 

broad groups of small entities that could 

be directly affected herein. First, while 

there are industry specific size 

standards for small businesses that are 

used in the regulatory flexibility 

analysis, according to data from the 

Small Business Administration’s (SBA) 

Office of Advocacy, in general a small 

business is an independent business 

having fewer than 500 employees. These 

types of small businesses represent 

99.9% of all businesses in the United 

States, which translates to 33.2 million 

businesses. 

146. Next, the type of small entity 

described as a ‘‘small organization’’ is 

generally ‘‘any not-for-profit enterprise 

which is independently owned and 

operated and is not dominant in its 

field.’’ The Internal Revenue Service 

(IRS) uses a revenue benchmark of 

$50,000 or less to delineate its annual 

electronic filing requirements for small 

exempt organizations. Nationwide, for 

tax year 2020, there were approximately 

447,689 small exempt organizations in 

the U.S. reporting revenues of $50,000 

or less according to the registration and 

tax data for exempt organizations 

available from the IRS. 

147. Finally, the small entity 

described as a ‘‘small governmental 

jurisdiction’’ is defined generally as 

‘‘governments of cities, counties, towns, 

townships, villages, school districts, or 

special districts, with a population of 

less than fifty thousand.’’ U.S. Census 

Bureau data from the 2017 Census of 

Governments indicate there were 90,075 

local governmental jurisdictions 

consisting of general purpose 

governments and special purpose 

governments in the United States. Of 

this number, there were 36,931 general 

purpose governments (county, 

municipal, and town or township) with 

populations of less than 50,000 and 

12,040 special purpose governments— 

independent school districts with 


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enrollment populations of less than 

50,000. Accordingly, based on the 2017 

U.S. Census of Governments data, we 

estimate that at least 48,971 entities fall 

into the category of ‘‘small 

governmental jurisdictions.’’ 

IV. Telecommunications Service 

Providers 

A. Wireless Telecommunications 

Providers 

148. Pursuant to 47 CFR 9.10(a), the 

Commission’s 911 service requirements 

are only applicable to CMRS providers, 

excluding mobile satellite service (MSS) 

operators, to the extent that they: (1) 

offer real-time, two way switched voice 

service that is interconnected with the 

public switched network; and (2) use an 

in-network switching facility that 

enables the provider to reuse 

frequencies and accomplish seamless 

hand-offs of subscriber calls. These 

requirements are applicable to entities 

that offer voice service to consumers by 

purchasing airtime or capacity at 

wholesale rates from CMRS licensees. 

149. Below, for those services subject 

to auctions, we note that, as a general 

matter, the number of winning bidders 

that qualify as small businesses at the 

close of an auction does not necessarily 

represent the number of small 

businesses currently in service. Also, 

the Commission does not generally track 

subsequent business size unless, in the 

context of assignments or transfers, 

unjust enrichment issues are implicated. 

150. All Other Telecommunications. 

This industry is comprised of 

establishments primarily engaged in 

providing specialized 

telecommunications services, such as 

satellite tracking, communications 

telemetry, and radar station operation. 

This industry also includes 

establishments primarily engaged in 

providing satellite terminal stations and 

associated facilities connected with one 

or more terrestrial systems and capable 

of transmitting telecommunications to, 

and receiving telecommunications from, 

satellite systems. Providers of internet 

services (e.g., dial-up internet service 

providers (ISPs)) or Voice over internet 

Protocol (VoIP) services, via clientsupplied telecommunications 

connections are also included in this 

industry. The SBA small business size 

standard for this industry classifies 

firms with annual receipts of $35 

million or less as small. U.S. Census 

Bureau data for 2017 show that there 

were 1,079 firms in this industry that 

operated for the entire year. Of those 

firms, 1,039 had revenue of less than 

$25 million. Based on this data, the 

Commission estimates that the majority 

of ‘‘All Other Telecommunications’’ 

firms can be considered small. 

151. Advanced Wireless Services 

(AWS)—(1710–1755 MHz and 2110– 

2155 MHz bands (AWS–1); 1915–1920 

MHz, 1995–2000 MHz, 2020–2025 MHz 

and 2175–2180 MHz bands (AWS–2); 

2155–2175 MHz band (AWS–3); 2000– 

2020 MHz and 2180–2200 MHz (AWS– 

4)). Spectrum is made available and 

licensed in these bands for the provision 

of various wireless communications 

services. Wireless Telecommunications 

Carriers (except Satellite) is the closest 

industry with an SBA small business 

size standard applicable to these 

services. The SBA small business size 

standard for this industry classifies a 

business as small if it has 1,500 or fewer 

employees. U.S. Census Bureau data for 

2017 show that there were 2,893 firms 

that operated in this industry for the 

entire year. Of this number, 2,837 firms 

employed fewer than 250 employees. 

Thus, under the SBA size standard, the 

Commission estimates that a majority of 

licensees in this industry can be 

considered small. 

152. According to Commission data as 

December 2021, there were 

approximately 4,472 active AWS 

licenses. The Commission’s small 

business size standards with respect to 

AWS involve eligibility for bidding 

credits and installment payments in the 

auction of licenses for these services. 

For the auction of AWS licenses, the 

Commission defined a ‘‘small business’’ 

as an entity with average annual gross 

revenues for the preceding three years 

not exceeding $40 million, and a ‘‘very 

small business’’ as an entity with 

average annual gross revenues for the 

preceding three years not exceeding $15 

million. Pursuant to these definitions, 

57 winning bidders claiming status as 

small or very small businesses won 215 

of 1,087 licenses. In the most recent 

auction of AWS licenses 15 of 37 

bidders qualifying for status as small or 

very small businesses won licenses. 

153. In frequency bands where 

licenses were subject to auction, the 

Commission notes that as a general 

matter, the number of winning bidders 

that qualify as small businesses at the 

close of an auction does not necessarily 

represent the number of small 

businesses currently in service. Further, 

the Commission does not generally track 

subsequent business size unless, in the 

context of assignments or transfers, 

unjust enrichment issues are implicated. 

Additionally, since the Commission 

does not collect data on the number of 

employees for licensees providing these 

services, at this time we are not able to 

estimate the number of licensees with 

active licenses that would qualify as 

small under the SBA’s small business 

size standard. 

154. Competitive Local Exchange 

Carriers (LECs). Neither the Commission 

nor the SBA has developed a size 

standard for small businesses 

specifically applicable to local exchange 

services. Providers of these services 

include several types of competitive 

local exchange service providers. Wired 

Telecommunications Carriers is the 

closest industry with an SBA small 

business size standard. The SBA small 

business size standard for Wired 

Telecommunications Carriers classifies 

firms having 1,500 or fewer employees 

as small. U.S. Census Bureau data for 

2017 show that there were 3,054 firms 

that operated in this industry for the 

entire year. Of this number, 2,964 firms 

operated with fewer than 250 

employees. Additionally, based on 

Commission data in the 2022 Universal 

Service Monitoring Report, as of 

December 31, 2021, there were 3,378 

providers that reported they were 

competitive local exchange service 

providers. Of these providers, the 

Commission estimates that 3,230 

providers have 1,500 or fewer 

employees. Consequently, using the 

SBA’s small business size standard, 

most of these providers can be 

considered small entities. 

155. Incumbent Local Exchange 

Carriers (Incumbent LECs). Neither the 

Commission nor the SBA have 

developed a small business size 

standard specifically for incumbent 

local exchange carriers. Wired 

Telecommunications Carriers is the 

closest industry with an SBA small 

business size standard. The SBA small 

business size standard for Wired 

Telecommunications Carriers classifies 

firms having 1,500 or fewer employees 

as small. U.S. Census Bureau data for 

2017 show that there were 3,054 firms 

in this industry that operated for the 

entire year. Of this number, 2,964 firms 

operated with fewer than 250 

employees. Additionally, based on 

Commission data in the 2022 Universal 

Service Monitoring Report, as of 

December 31, 2021, there were 1,212 

providers that reported they were 

incumbent local exchange service 

providers. Of these providers, the 

Commission estimates that 916 

providers have 1,500 or fewer 

employees. Consequently, using the 

SBA’s small business size standard, the 

Commission estimates that the majority 

of incumbent local exchange carriers 

can be considered small entities. 

156. Broadband Personal 

Communications Service. The 

broadband personal communications 

services (PCS) spectrum encompasses 


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services in the 1850–1910 and 1930– 

1990 MHz bands. The closest industry 

with an SBA small business size 

standard applicable to these services is 

Wireless Telecommunications Carriers 

(except Satellite). The SBA small 

business size standard for this industry 

classifies a business as small if it has 

1,500 or fewer employees. U.S. Census 

Bureau data for 2017 show that there 

were 2,893 firms that operated in this 

industry for the entire year. Of this 

number, 2,837 firms employed fewer 

than 250 employees. Thus, under the 

SBA size standard, the Commission 

estimates that a majority of licensees in 

this industry can be considered small. 

157. Based on Commission data as of 

November 2021, there were 

approximately 5,060 active licenses in 

the Broadband PCS service. The 

Commission’s small business size 

standards with respect to Broadband 

PCS involve eligibility for bidding 

credits and installment payments in the 

auction of licenses for these services. In 

auctions for these licenses, the 

Commission defined ‘‘small business’’ 

as an entity that, together with its 

affiliates and controlling interests, has 

average gross revenues not exceeding 

$40 million for the preceding three 

years, and a ‘‘very small business’’ as an 

entity that, together with its affiliates 

and controlling interests, has had 

average annual gross revenues not 

exceeding $15 million for the preceding 

three years. Winning bidders claiming 

small business credits won Broadband 

PCS licenses in C, D, E, and F Blocks. 

158. In frequency bands where 

licenses were subject to auction, the 

Commission notes that as a general 

matter, the number of winning bidders 

that qualify as small businesses at the 

close of an auction does not necessarily 

represent the number of small 

businesses currently in service. Further, 

the Commission does not generally track 

subsequent business size unless, in the 

context of assignments or transfers, 

unjust enrichment issues are implicated. 

Additionally, since the Commission 

does not collect data on the number of 

employees for licensees providing these, 

at this time we are not able to estimate 

the number of licensees with active 

licenses that would qualify as small 

under the SBA’s small business size 

standard. 

159. Narrowband Personal 

Communications Services. Narrowband 

Personal Communications Services 

(Narrowband PCS) are PCS services 

operating in the 901–902 MHz, 930–931 

MHz, and 940–941 MHz bands. PCS 

services are radio communications that 

encompass mobile and ancillary fixed 

communication that provide services to 

individuals and businesses and can be 

integrated with a variety of competing 

networks. Wireless Telecommunications 

Carriers (except Satellite) is the closest 

industry with an SBA small business 

size standard applicable to these 

services. The SBA small business size 

standard for this industry classifies a 

business as small if it has 1,500 or fewer 

employees. U.S. Census Bureau data for 

2017 show that there were 2,893 firms 

that operated in this industry for the 

entire year. Of this number, 2,837 firms 

employed fewer than 250 employees. 

Thus, under the SBA size standard, the 

Commission estimates that a majority of 

licensees in this industry can be 

considered small. 

160. According to Commission data as 

of December 2021, there were 

approximately 4,211 active Narrowband 

PCS licenses. The Commission’s small 

business size standards with respect to 

Narrowband PCS involve eligibility for 

bidding credits and installment 

payments in the auction of licenses for 

these services. For the auction of these 

licenses, the Commission defined a 

‘‘small business’’ as an entity that, 

together with affiliates and controlling 

interests, has average gross revenues for 

the three preceding years of not more 

than $40 million. A ‘‘very small 

business’’ is defined as an entity that, 

together with affiliates and controlling 

interests, has average gross revenues for 

the three preceding years of not more 

than $15 million. Pursuant to these 

definitions, 7 winning bidders claiming 

small and very small bidding credits 

won approximately 359 licenses. One of 

the winning bidders claiming a small 

business status classification in these 

Narrowband PCS license auctions had 

an active license as of December 2021. 

161. In frequency bands where 

licenses were subject to auction, the 

Commission notes that as a general 

matter, the number of winning bidders 

that qualify as small businesses at the 

close of an auction does not necessarily 

represent the number of small 

businesses currently in service. Further, 

the Commission does not generally track 

subsequent business size unless, in the 

context of assignments or transfers, 

unjust enrichment issues are implicated. 

Additionally, since the Commission 

does not collect data on the number of 

employees for licensees providing these 

services, at this time we are not able to 

estimate the number of licensees with 

active licenses that would qualify as 

small under the SBA’s small business 

size standard. 

162. Offshore Radiotelephone Service. 

This service operates on several ultra 

high frequency (UHF) television 

broadcast channels that are not used for 

television broadcasting in the coastal 

areas of states bordering the Gulf of 

Mexico. Wireless Telecommunications 

Carriers (except Satellite) is the closest 

industry with an SBA small business 

size standard applicable to this service. 

The SBA small business size standard 

for this industry classifies a business as 

small if it has 1,500 or fewer employees. 

U.S. Census Bureau data for 2017 show 

that there were 2,893 firms that operated 

in this industry for the entire year. Of 

this number, 2,837 firms employed 

fewer than 250 employees. Thus, under 

the SBA size standard, the Commission 

estimates that a majority of licensees in 

this industry can be considered small. 

Additionally, based on Commission 

data, as of December 2021, there was 

one licensee with an active license in 

this service. However, since the 

Commission does not collect data on the 

number of employees for this service, at 

this time we are not able to estimate the 

number of licensees that would qualify 

as small under the SBA’s small business 

size standard. 

163. Radio and Television 

Broadcasting and Wireless 

Communications Equipment 

Manufacturing. This industry comprises 

establishments primarily engaged in 

manufacturing radio and television 

broadcast and wireless communications 

equipment. Examples of products made 

by these establishments are: 

transmitting and receiving antennas, 

cable television equipment, Global 

Positioning System (GPS) equipment, 

pagers, cellular phones, mobile 

communications equipment, and radio 

and television studio and broadcasting 

equipment. The SBA small business size 

standard for this industry classifies 

businesses having 1,250 employees or 

less as small. U.S. Census Bureau data 

for 2017 show that there were 656 firms 

in this industry that operated for the 

entire year. Of this number, 624 firms 

had fewer than 250 employees. Thus, 

under the SBA size standard, the 

majority of firms in this industry can be 

considered small. 

164. Rural Radiotelephone Service. 

Neither the Commission nor the SBA 

have developed a small business size 

standard specifically for small 

businesses providing Rural 

Radiotelephone Service. Rural 

Radiotelephone Service is radio service 

in which licensees are authorized to 

offer and provide radio 

telecommunication services for hire to 

subscribers in areas where it is not 

feasible to provide communication 

services by wire or other means. A 

significant subset of the Rural 

Radiotelephone Service is the Basic 

Exchange Telephone Radio System 


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(BETRS). Wireless Telecommunications 

Carriers (except Satellite) is the closest 

applicable industry with an SBA small 

business size standard. The SBA small 

business size standard for Wireless 

Telecommunications Carriers (except 

Satellite) classifies firms having 1,500 or 

fewer employees as small. For this 

industry, U.S. Census Bureau data for 

2017 show that there were 2,893 firms 

that operated for the entire year. Of this 

total, 2,837 firms employed fewer than 

250 employees. Thus, under the SBA 

size standard, the Commission estimates 

that the majority of Rural 

Radiotelephone Services firm are small 

entities. Based on Commission data as 

of December 27, 2021, there were 

approximately 119 active licenses in the 

Rural Radiotelephone Service. The 

Commission does not collect 

employment data from these entities 

holding these licenses and therefore we 

cannot estimate how many of these 

entities meet the SBA small business 

size standard. 

165. Wireless Communications 

Services. Wireless Communications 

Services (WCS) can be used for a variety 

of fixed, mobile, radiolocation, and 

digital audio broadcasting satellite 

services. Wireless spectrum is made 

available and licensed for the provision 

of wireless communications services in 

several frequency bands subject to part 

27 of the Commission’s rules. Wireless 

Telecommunications Carriers (except 

Satellite) is the closest industry with an 

SBA small business size standard 

applicable to these services. The SBA 

small business size standard for this 

industry classifies a business as small if 

it has 1,500 or fewer employees. U.S. 

Census Bureau data for 2017 show that 

there were 2,893 firms that operated in 

this industry for the entire year. Of this 

number, 2,837 firms employed fewer 

than 250 employees. Thus, under the 

SBA size standard, the Commission 

estimates that a majority of licensees in 

this industry can be considered small. 

166. The Commission’s small 

business size standards with respect to 

WCS involve eligibility for bidding 

credits and installment payments in the 

auction of licenses for the various 

frequency bands included in WCS. 

When bidding credits are adopted for 

the auction of licenses in WCS 

frequency bands, such credits may be 

available to several types of small 

businesses based average gross revenues 

(small, very small and entrepreneur) 

pursuant to the competitive bidding 

rules adopted in conjunction with the 

requirements for the auction and/or as 

identified in the designated entities 

section in part 27 of the Commission’s 

rules for the specific WCS frequency 

bands. 

167. In frequency bands where 

licenses were subject to auction, the 

Commission notes that as a general 

matter, the number of winning bidders 

that qualify as small businesses at the 

close of an auction does not necessarily 

represent the number of small 

businesses currently in service. Further, 

the Commission does not generally track 

subsequent business size unless, in the 

context of assignments or transfers, 

unjust enrichment issues are implicated. 

Additionally, since the Commission 

does not collect data on the number of 

employees for licensees providing these 

services, at this time we are not able to 

estimate the number of licensees with 

active licenses that would qualify as 

small under the SBA’s small business 

size standard. 

168. Wireless Telecommunications 

Carriers (except Satellite). This industry 

comprises establishments engaged in 

operating and maintaining switching 

and transmission facilities to provide 

communications via the airwaves. 

Establishments in this industry have 

spectrum licenses and provide services 

using that spectrum, such as cellular 

services, paging services, wireless 

internet access, and wireless video 

services. The SBA size standard for this 

industry classifies a business as small if 

it has 1,500 or fewer employees. U.S. 

Census Bureau data for 2017 show that 

there were 2,893 firms in this industry 

that operated for the entire year. Of that 

number, 2,837 firms employed fewer 

than 250 employees. Additionally, 

based on Commission data in the 2022 

Universal Service Monitoring Report, as 

of December 31, 2021, there were 594 

providers that reported they were 

engaged in the provision of wireless 

services. Of these providers, the 

Commission estimates that 511 

providers have 1,500 or fewer 

employees. Consequently, using the 

SBA’s small business size standard, 

most of these providers can be 

considered small entities. 

169. Wireless Telephony. Wireless 

telephony includes cellular, personal 

communications services, and 

specialized mobile radio telephony 

carriers. The closest applicable industry 

with an SBA small business size 

standard is Wireless 

Telecommunications Carriers (except 

Satellite). The size standard for this 

industry under SBA rules is that a 

business is small if it has 1,500 or fewer 

employees. For this industry, U.S. 

Census Bureau data for 2017 show that 

there were 2,893 firms that operated for 

the entire year. Of this number, 2,837 

firms employed fewer than 250 

employees. Additionally, based on 

Commission data in the 2022 Universal 

Service Monitoring Report, as of 

December 31, 2021, there were 331 

providers that reported they were 

engaged in the provision of cellular, 

personal communications services, and 

specialized mobile radio services. Of 

these providers, the Commission 

estimates that 255 providers have 1,500 

or fewer employees. Consequently, 

using the SBA’s small business size 

standard, most of these providers can be 

considered small entities. 

170. 700 MHz Guard Band Licensees. 

The 700 MHz Guard Band encompasses 

spectrum in 746–747/776–777 MHz and 

762–764/792–794 MHz frequency 

bands. Wireless Telecommunications 

Carriers (except Satellite) is the closest 

industry with an SBA small business 

size standard applicable to licenses 

providing services in these bands. The 

SBA small business size standard for 

this industry classifies a business as 

small if it has 1,500 or fewer employees. 

U.S. Census Bureau data for 2017 show 

that there were 2,893 firms that operated 

in this industry for the entire year. Of 

this number, 2,837 firms employed 

fewer than 250 employees. Thus, under 

the SBA size standard, the Commission 

estimates that a majority of licensees in 

this industry can be considered small. 

171. According to Commission data as 

of December 2021, there were 

approximately 224 active 700 MHz 

Guard Band licenses. The Commission’s 

small business size standards with 

respect to 700 MHz Guard Band 

licensees involve eligibility for bidding 

credits and installment payments in the 

auction of licenses. For the auction of 

these licenses, the Commission defined 

a ‘‘small business’’ as an entity that, 

together with its affiliates and 

controlling principals, has average gross 

revenues not exceeding $40 million for 

the preceding three years, and a ‘‘very 

small business’’ an entity that, together 

with its affiliates and controlling 

principals, has average gross revenues 

that are not more than $15 million for 

the preceding three years. Pursuant to 

these definitions, five winning bidders 

claiming one of the small business 

status classifications won 26 licenses, 

and one winning bidder claiming small 

business won two licenses. None of the 

winning bidders claiming a small 

business status classification in these 

700 MHz Guard Band license auctions 

had an active license as of December 

2021. 

172. In frequency bands where 

licenses were subject to auction, the 

Commission notes that as a general 

matter, the number of winning bidders 

that qualify as small businesses at the 


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close of an auction does not necessarily 

represent the number of small 

businesses currently in service. Further, 

the Commission does not generally track 

subsequent business size unless, in the 

context of assignments or transfers, 

unjust enrichment issues are implicated. 

Additionally, since the Commission 

does not collect data on the number of 

employees for licensees providing these 

services, at this time we are not able to 

estimate the number of licensees with 

active licenses that would qualify as 

small under the SBA’s small business 

size standard. 

173. Lower 700 MHz Band Licenses. 

The lower 700 MHz band encompasses 

spectrum in the 698–746 MHz 

frequency bands. Permissible operations 

in these bands include flexible fixed, 

mobile, and broadcast uses, including 

mobile and other digital new broadcast 

operation; fixed and mobile wireless 

commercial services (including 

frequency division duplex (FDD)- and 

time division duplex (TDD)-based 

services); as well as fixed and mobile 

wireless uses for private, internal radio 

needs, two-way interactive, cellular, and 

mobile television broadcasting services. 

Wireless Telecommunications Carriers 

(except Satellite) is the closest industry 

with an SBA small business size 

standard applicable to licenses 

providing services in these bands. The 

SBA small business size standard for 

this industry classifies a business as 

small if it has 1,500 or fewer employees. 

U.S. Census Bureau data for 2017 show 

that there were 2,893 firms that operated 

in this industry for the entire year. Of 

this number, 2,837 firms employed 

fewer than 250 employees. Thus, under 

the SBA size standard, the Commission 

estimates that a majority of licensees in 

this industry can be considered small. 

174. According to Commission data as 

of December 2021, there were 

approximately 2,824 active Lower 700 

MHz Band licenses. The Commission’s 

small business size standards with 

respect to Lower 700 MHz Band 

licensees involve eligibility for bidding 

credits and installment payments in the 

auction of licenses. For auctions of 

Lower 700 MHz Band licenses the 

Commission adopted criteria for three 

groups of small businesses. A very small 

business was defined as an entity that, 

together with its affiliates and 

controlling interests, has average annual 

gross revenues not exceeding $15 

million for the preceding three years, a 

small business was defined as an entity 

that, together with its affiliates and 

controlling interests, has average gross 

revenues not exceeding $40 million for 

the preceding three years, and an 

entrepreneur was defined as an entity 

that, together with its affiliates and 

controlling interests, has average gross 

revenues not exceeding $3 million for 

the preceding three years. In auctions 

for Lower 700 MHz Band licenses 

seventy-two winning bidders claiming a 

small business classification won 329 

licenses, twenty-six winning bidders 

claiming a small business classification 

won 214 licenses, and three winning 

bidders claiming a small business 

classification won all five auctioned 

licenses. 

175. In frequency bands where 

licenses were subject to auction, the 

Commission notes that as a general 

matter, the number of winning bidders 

that qualify as small businesses at the 

close of an auction does not necessarily 

represent the number of small 

businesses currently in service. Further, 

the Commission does not generally track 

subsequent business size unless, in the 

context of assignments or transfers, 

unjust enrichment issues are implicated. 

Additionally, since the Commission 

does not collect data on the number of 

employees for licensees providing these 

services, at this time we are not able to 

estimate the number of licensees with 

active licenses that would qualify as 

small under the SBA’s small business 

size standard. 

176. Upper 700 MHz Band Licenses. 

The upper 700 MHz band encompasses 

spectrum in the 746–806 MHz bands. 

Upper 700 MHz D Block licenses are 

nationwide licenses associated with the 

758–763 MHz and 788–793 MHz bands. 

Permissible operations in these bands 

include flexible fixed, mobile, and 

broadcast uses, including mobile and 

other digital new broadcast operation; 

fixed and mobile wireless commercial 

services (including FDD- and TDDbased services); as well as fixed and 

mobile wireless uses for private, 

internal radio needs, two-way 

interactive, cellular, and mobile 

television broadcasting services. 

Wireless Telecommunications Carriers 

(except Satellite) is the closest industry 

with an SBA small business size 

standard applicable to licenses 

providing services in these bands. The 

SBA small business size standard for 

this industry classifies a business as 

small if it has 1,500 or fewer employees. 

U.S. Census Bureau data for 2017 show 

that there were 2,893 firms that operated 

in this industry for the entire year. Of 

that number, 2,837 firms employed 

fewer than 250 employees. Thus, under 

the SBA size standard, the Commission 

estimates that a majority of licensees in 

this industry can be considered small. 

177. According to Commission data as 

of December 2021, there were 

approximately 152 active Upper 700 

MHz Band licenses. The Commission’s 

small business size standards with 

respect to Upper 700 MHz Band 

licensees involve eligibility for bidding 

credits and installment payments in the 

auction of licenses. For the auction of 

these licenses, the Commission defined 

a ‘‘small business’’ as an entity that, 

together with its affiliates and 

controlling principals, has average gross 

revenues not exceeding $40 million for 

the preceding three years, and a ‘‘very 

small business’’ an entity that, together 

with its affiliates and controlling 

principals, has average gross revenues 

that are not more than $15 million for 

the preceding three years. Pursuant to 

these definitions, three winning bidders 

claiming very small business status won 

five of the twelve available licenses. 

178. In frequency bands where 

licenses were subject to auction, the 

Commission notes that as a general 

matter, the number of winning bidders 

that qualify as small businesses at the 

close of an auction does not necessarily 

represent the number of small 

businesses currently in service. Further, 

the Commission does not generally track 

subsequent business size unless, in the 

context of assignments or transfers, 

unjust enrichment issues are implicated. 

Additionally, since the Commission 

does not collect data on the number of 

employees for licensees providing these 

services, at this time we are not able to 

estimate the number of licensees with 

active licenses that would qualify as 

small under the SBA’s small business 

size standard. 

179. Wireless Resellers. Neither the 

Commission nor the SBA have 

developed a small business size 

standard specifically for Wireless 

Resellers. The closest industry with an 

SBA small business size standard is 

Telecommunications Resellers. The 

Telecommunications Resellers industry 

comprises establishments engaged in 

purchasing access and network capacity 

from owners and operators of 

telecommunications networks and 

reselling wired and wireless 

telecommunications services (except 

satellite) to businesses and households. 

Establishments in this industry resell 

telecommunications and they do not 

operate transmission facilities and 

infrastructure. Mobile virtual network 

operators (MVNOs) are included in this 

industry. Under the SBA size standard 

for this industry, a business is small if 

it has 1,500 or fewer employees. U.S. 

Census Bureau data for 2017 show that 

1,386 firms in this industry provided 

resale services during that year. Of that 

number, 1,375 firms operated with 

fewer than 250 employees. Thus, for 

this industry under the SBA small 


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business size standard, the majority of 

providers can be considered small 

entities. 

B. Equipment Manufacturers 

180. Radio and Television 

Broadcasting and Wireless 

Communications Equipment 

Manufacturing. This industry comprises 

establishments primarily engaged in 

manufacturing radio and television 

broadcast and wireless communications 

equipment. Examples of products made 

by these establishments are: 

transmitting and receiving antennas, 

cable television equipment, GPS 

equipment, pagers, cellular phones, 

mobile communications equipment, and 

radio and television studio and 

broadcasting equipment. The SBA small 

business size standard for this industry 

classifies businesses having 1,250 

employees or less as small. U.S. Census 

Bureau data for 2017 show that there 

were 656 firms in this industry that 

operated for the entire year. Of this 

number, 624 firms had fewer than 250 

employees. Thus, under the SBA size 

standard, the majority of firms in this 

industry can be considered small. 

181. Semiconductor and Related 

Device Manufacturing. This industry 

comprises establishments primarily 

engaged in manufacturing 

semiconductors and related solid state 

devices. Examples of products made by 

these establishments are integrated 

circuits, memory chips, 

microprocessors, diodes, transistors, 

solar cells and other optoelectronic 

devices. The SBA small business size 

standard for this industry classifies 

entities having 1,250 or fewer 

employees as small. U.S. Census Bureau 

data for 2017 show that there were 729 

firms in this industry that operated for 

the entire year. Of this total, 673 firms 

operated with fewer than 250 

employees. Thus, under the SBA size 

standard, the majority of firms in this 

industry can be considered small. 

C. Description of Projected Reporting, 

Recordkeeping, and Other Compliance 

Requirements for Small Entities 

182. The rules adopted to implement 

location-based routing for wireless 911 

voice calls and RTT communications to 

911 will impose new or additional 

reporting, recordkeeping, and/or other 

compliance obligations on small 

entities. Small and other CMRS 

providers are required to certify their 

compliance with the applicable 

location-based routing requirements, 

and inform the Commission of the 

specific network architecture, systems, 

and location validation procedures used 

to comply with the location-based 

routing requirements. More specifically, 

the adopted rules require small and 

other CMRS providers, within 60 days 

after their respective deadlines, to 

deploy location-based routing on their 

IP-based networks, and submit a onetime certification with substantiating 

evidence of compliance with locationbased routing requirements applicable 

to them as of the deadline. As part of the 

certification, small and other CMRS 

providers must: (i) substantiate 

compliance by identifying specific 

network architecture, systems, location 

validation, and procedures used to 

comply with the location-based routing 

rules; (ii) collect and report aggregate 

information on the routing technologies 

for all live wireless 911 voice calls in 

the locations specified for live 911 call 

location data under the Commission’s 

rule at 47 CFR 9.10(i)(3)(ii); and (iii) 

certify that location information used 

for location-based routing by service 

providers and third parties will only be 

used for valid 911 purposes. Small and 

other CMRS providers can request 

confidential treatment of any 

information they submit in accordance 

with the Commission’s confidentiality 

rules. 

183. In the NPRM, the Commission 

sought comments on the proposals in 

this proceeding and requested cost and 

benefit information to help the 

Commission identify and evaluate 

relevant matters for small entities. 

Although several comments filed in 

response to the NPRM discussed 

categories of potential expenses to 

comply with location-based routing 

requirements, and any related reporting 

and recordkeeping requirements, with 

some asserting that there would be a 

greater burden on smaller providers, 

these comments and the record as a 

whole do not contain detailed 

information on costs required for either 

small or large entities. In fact, the Rural 

Wireless Association (RWA) and the 

Boulder Regional Emergency Telephone 

Service Authority (BRETSA) expressly 

indicated that neither non-nationwide 

nor small carriers have determined their 

implementation costs. Moreover, while 

stating that ‘‘[t]he $366,600 figure 

referenced in the NPRM may be a 

conservative estimate,’’ RWA did not 

provide an alternative to the 

Commission’s estimate and noted that to 

date, RWA members have not received 

any specific vendor estimates regarding 

their actual cost of compliance. 

184. In the NPRM, the Commission 

proposed an ‘‘upper bound’’ estimate for 

labor costs of $366,600 per CMRS 

provider, and for material costs such as 

software features or component 

upgrades for each CMRS provider, of 

$10,000 per PSAP. In response to the 

comments we received, we clarify that 

material costs estimated in the NPRM 

are not limited to those incurred at the 

PSAP, but also in the network core, and 

that the per PSAP calculation is a proxy 

for the size of the network that remains 

to be converted to location-based 

routing. Using the Commission’s 

methodology in the NPRM, we estimate 

that CMRS providers collectively need 

to deploy location-based routing to a 

total of 14,366 PSAPs, resulting in the 

implied material cost of approximately 

$143.7 million. 

185. Our total labor costs analysis 

added internal planning, outreach, and 

testing to the costs for equipment 

installation and conducting trials the 

Commission proposed and discussed in 

the NPRM. To better reflect the wide 

array of complex tasks that will be 

undertaken with highly skilled and 

senior staff, we will assume a higher 

wage for the workers than that assumed 

in the NPRM because some of the tasks 

involved will have to be undertaken by 

senior staff. Using the Bureau of Labor 

Statistics 75th percentile wage for 

network engineers, we assume worker 

compensation to be $81.29 per hour. 

Marking up hourly compensation by 

45% to account for benefits results in a 

total hourly compensation estimate of 

$117.87. Assuming that work is 

completed over 26 work-weeks of five, 

8 work-hour days, and a team of 10, the 

aggregate upper bound of work-hours 

would 10,400 and the total cost of those 

work-hours would be $1,225,853. While 

non-nationwide CMRS providers will 

have 24 months rather than six to 

implement location-based routing, 

smaller CMRS providers have 

constraints on the number of staff they 

can assign to any one project. In 

addition, while non-nationwide CMRS 

providers may take longer to implement 

location-based routing, assigning the 

same amount of work-time as 

nationwide CMRS providers represents 

both the spreading out of tasks over a 

longer period and an overestimate since 

non-nationwide CMRS providers have 

much smaller networks. Given that 

AT&T has already implemented 

location-based routing, we estimate the 

labor cost associated with 

implementation for network for the 56 

remaining providers, plus T-Mobile and 

Verizon, to be $71 million (≈ $1,225,853 

× 58 providers = $71,099,474). 

186. In addition to network costs, 

several commenters indicate that public 

safety-grade GIS data or shapefiles that 

precisely define PSAP boundaries 

should be developed or provided, 

though they differ on which parties 

should be responsible. We agree with 


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NENA that it is the responsibility of 

providers to maintain their own 

jurisdictional maps. Accordingly, we 

assign the cost of maps to the providers. 

We anticipate that map costs will 

largely be labor to update already 

existing maps. To come up with a cost 

ceiling, we assume that every provider 

will need to update its maps, even 

though many providers likely have upto-date maps. We anticipate that 

updating the map will only entail labor 

costs for mapping specialists to update 

maps. In the Supporting Document of 

Study Area Boundary Data Reporting in 

Esri Shapefile Format, the Office of 

Information and Regulatory Affairs 

estimates that it takes an average of 26 

hours for a data scientist to modify a 

shapefile. We believe that 26 hours 

would be an upper bound of the time 

required for a party to update its maps. 

Given that the average wage rate is 

$60.44/hour for data scientists in the 

telecommunications industry, with a 

45% markup for benefits, we arrive at 

$87.63 as the hourly compensation rate 

for a data scientist. We estimate an 

upper bound for the cost of map 

updating to be approximately $134,000 

(≈ $87.63 per hour × 26 hours × 59 

providers = $134,424.42). 

187. In addition, the one-time 

certification of compliance with our 

requirements together with the 

submission of data on call percentages 

by routing methods will impose a onetime cost on CMRS providers. As this 

required information should be 

available to each provider internally, we 

anticipate work to compile this 

information to take no longer than a 

week of five business days. We believe 

that one network engineer would be 

sufficient to complete this task in this 

time frame, resulting in a total provider 

cost of 40 work-hours. Assuming the 

same hourly labor cost of network 

engineers as in the previous cost 

estimate for network implementation, 

the total cost of reporting is $280,000 (≈ 

$117.87 per hour × 40 hours × 59 

providers = $278,173.20). 

188. Because we are adopting 

location-based routing requirements for 

RTT communications to 911, we also 

consider the costs for CMRS providers. 

Given that CMRS providers process and 

route RTT communications to 911 

similarly to voice calls, we assume that 

CMRS providers’ material and labor 

costs to deploy location-based routing 

for RTT are included in our cost 

estimates above. As part of this analysis, 

we note that as of the release date of the 

Report and Order, we are aware of only 

a small number of PSAPs that are 

receiving RTT communications. 

189. In sum, we estimate upper 

bounds of the costs that CMRS 

providers will bear to be material costs 

of $143.7 million, network 

implementation costs of $71.1 million, 

GIS costs of $134,000, and certification 

costs of $280,000. Altogether, the upper 

bound of costs is approximately $215 

million. We note that the three major 

CMRS providers (AT&T, T-Mobile, and 

Verizon) have already implemented 

location-based routing for wireless 911 

voice calls nationwide, or are in the 

process of implementing it. Although 

some commenters argue that this 

progress by three major carriers will not 

necessarily translate into reduced costs 

and greater efficiency for smaller 

providers to implement location-based 

routing, it appears that this progress by 

larger providers may have at least some 

measure of positive impact on 

implementation by smaller providers, 

such as by demonstrating potential 

implementation technologies and 

strategies, although they may be 

required to hire professionals to fulfill 

their compliance obligations. 

190. The important public safety 

benefits that will result from the 

requirements the Commission adopted 

outweigh the associated implementation 

and compliance burdens for CMRS 

providers. The rule changes to 

implement nationwide location-based 

routing will significantly decrease 

misrouted wireless 911 calls and RTT 

communications to 911, reduce 

emergency response time, save lives, 

and save many PSAP personnel hours 

and resources lost in 911 transfers. 

Accordingly, these rule changes serve 

the public interest. 

D. Steps Taken To Minimize the 

Significant Economic Impact on Small 

Entities, and Significant Alternatives 

Considered 

191. The RFA requires an agency to 

provide ‘‘a description of the steps the 

agency has taken to minimize the 

significant economic impact on small 

entities . . . including a statement of 

the factual, policy, and legal reasons for 

selecting the alternative adopted in the 

final rule and why each one of the other 

significant alternatives to the rule 

considered by the agency which affect 

the impact on small entities was 

rejected.’’ 

192. In the previous section we 

described the significant public safety 

benefits to be achieved from requiring 

all CMRS providers to implement 

location-based routing for wireless 911 

voice calls and RTT messages 

originating on IP-based networks on a 

nationwide basis. From the record in 

this proceeding, it appears to be 

technologically feasible for CMRS 

providers to implement location-based 

routing for a significant percentage of 

wireless 911 voice calls and RTT 

messages. In the Report and Order we 

expressly found that it is 

technologically feasible for all CMRS 

providers, nationwide and nonnationwide, to support location-based 

routing for a significant percentage of 

wireless 911 voice calls. The 

Commission considered comments 

advocating for a voluntary locationbased routing approach to allow 

providers the flexibility which would 

take into account the differences in 

providers’ networks, configurations and 

devices. We found, however, that 

implementing location-based routing on 

a voluntary basis is not consistent with 

the Commission’s goal of ensuring that 

location-based routing is available to all 

wireless 911 callers on a nationwide 

basis. Accordingly, the rules we adopt 

require both nationwide and nonnationwide CMRS providers to 

implement location-based routing 

consistent with the proposals in the 

NPRM. 

193. The Commission also considered 

a per-PSAP approach to implement 

location-based routing but determined 

that there could be uneven and 

inconsistent implementation in routing 

approaches between jurisdictions, and 

there was also a risk of 911 misroutes 

for jurisdictions that do not request 

location-based routing service. The 

Commission found that a per-PSAP 

approach was not consistent with its 

interest in facilitating improved routing 

of 911 voice calls, and was not in the 

public interest. Additionally, we 

determined this approach would impose 

unnecessary cost burdens on PSAPs to 

affirmatively request such service. The 

rules we adopted in the Report and 

Order were intended to be cost effective 

and minimally burdensome for small 

and other entities impacted by the rules. 

Below we discuss the specific steps the 

Commission has taken to minimize 

costs and reduce the economic impact 

for small entities, as well as various 

alternatives considered. 

194. Location-Based Routing 

Requirements. Consistent with the 

Commission’s proposal in the NPRM 

and to reduce potential cost burdens for 

small and other wireless providers, our 

location-based routing rules apply only 

to wireless 911 voice calls and RTT 

communications originating on IP-based 

networks (i.e., 4G LTE, 5G, and 

subsequent generations of IP-based 

networks). The record indicated that 

while nationwide CMRS providers are 

in the process of retiring or have 

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switched, time-division multiplex 

(TDM) 2G and 3G networks, and some 

non-nationwide providers announced 

dates to sunset their 3G networks in 

2022, the transition from these networks 

that are less compatible with locationbased routing has not been fully 

completed. In the NPRM, the 

Commission tentatively concluded that 

requiring location-based routing for 911 

calls or texts originating on TDM-based 

networks would be unduly burdensome, 

especially for non-nationwide providers 

who would bear the greatest burden, 

even if given additional time to comply 

with such a requirement. Moreover, 

although the Commission considered 

requiring location-based routing for all 

911 calls, the Commission in the NPRM 

ultimately proposed to require locationbased routing only for 911 calls 

originating on IP-based networks, i.e., 

4G LTE, 5G, and subsequently deployed 

IP-based networks. In the Report and 

Order, the Commission adopted the 

proposed rule which will minimize 

some burdens and economic impact for 

small entities, particularly those that are 

non-nationwide providers, due to the 

limited scope of the requirement. 

195. Rather than imposing a rigid 

location-based routing requirement, the 

rules the Commission adopted provide 

flexibility to small and other entities to 

route wireless 911 voice calls or RTT 

communications based on the best 

available location information (which 

may include cell tower coordinates or 

other information) when the location 

information available at time of routing 

does not meet either one or both of the 

rules’ requirements for accuracy and 

timeliness. The Commission recognized 

the continued need for legacy E911 

routing, at least as a fallback method, 

because accurate device location 

information is not available in all 

scenarios. Further, the Commission’s 

requirement to default to best available 

location is consistent with the ATIS– 

0500039 standard for location-based 

routing, which assumes that the fallback 

for location-based routing should be 

cell-sector routing for cases where no 

position estimate is available in time to 

be used for location-based routing, or 

the position estimates lack requisite 

accuracy. Our requirement is also 

consistent with current CMRS provider 

deployments of location-based routing, 

which default to legacy E911 routing 

when location does not meet CMRS 

providers’ standards of accuracy and 

timeliness. 

196. The Report and Order also 

adopted baseline requirements 

involving the accuracy and timeliness of 

location information used for locationbased routing that are consistent with 

industry standards. Under the rules 

adopted, CMRS providers must use 

location-based routing only if the 

location information is available to the 

provider network at the time the 

wireless 911 voice call or RTT 

communication is routed, and the 

information identifies the caller’s 

horizontal location with a radius of 165 

meters at a confidence level of at least 

90%. These metrics are consistent with 

AT&T’s successful nationwide 

implementation of location-based 

routing, and received support as a 

model for other wireless carriers to 

implement location-based routing. In 

addition, the rule’s confidence metric is 

consistent with ATIS’s recommendation 

that uncertainty values for locationbased routing ‘‘be standardized to a 90% 

confidence for effective call handling.’’ 

When location information does not 

meet the baseline accuracy and 

timeliness requirements, the adopted 

requirements allow CMRS providers to 

instead route based on best available 

location information, which may 

include device-based location 

information that does not meet the 

accuracy threshold, the centroid of the 

area served by the cell sector that first 

picks up the call, or other location 

information. This will help to minimize 

any significant economic impact on 

small entities and other CMRS 

providers. 

197. Compliance Timelines. The rules 

adopted in the Report and Order 

provide small and other providers 

flexibility in the compliance timelines 

to implement the location-based routing 

requirements, which should reduce the 

economic burden for small entities. The 

compliance timelines differ from those 

the Commission proposed in the NPRM, 

which provided different deadlines for 

nationwide CMRS providers and nonnationwide CMRS providers to 

implement location-based routing on 

their IP-based networks when available 

location information meets 

requirements for accuracy and 

timeliness. To further reduce the burden 

on small entities in the rules adopted, 

the Commission granted longer 

compliance timelines to non-nationwide 

CMRS providers than those proposed in 

the NPRM and eliminated the 

requirements for covered text providers 

that are not CMRS providers. 

Specifically, non-nationwide CMRS 

providers (which includes a substantial 

number of small entities) are required to 

implement location-based routing for 

wireless 911 voice calls within 24 

months from the effective date of the 

final rules, rather than 18 months as 

proposed in the NPRM. Nationwide 

CMRS providers are required to 

implement location-based routing for 

wireless 911 voice calls within six 

months from the effective date of the 

final rules. For RTT, all CMRS providers 

are required to implement locationbased routing for RTT messages where 

they implement RTT capability within 

24 months from the effective date of the 

final rules, rather than the 12 months 

proposed in the NPRM. 

198. The Commission has also 

minimized any significant economic 

impact on small entities by limiting the 

requirement to implement locationbased routing to operators of IP-based 

networks only when certain 

requirements are met. Small entities are 

not required to comply with the 

location-based routing requirement if 

they do not operate an IP-based 

network, or if the location information 

available on the IP-based network does 

not meet either one or both of the 

requirements for timeliness and 

accuracy, in which case, small entities 

may use the best available location 

information for routing. Small entities 

will further benefit from the 

Commission’s adoption of provisions 

that allow PSAPs and CMRS providers 

to enter into agreements that establish 

an alternate timeframe for meeting the 

location-based routing requirements. 

The flexibility to negotiate an 

alternative timeframe that meets a 

CMRS provider’s business and financial 

needs is a significant step by the 

Commission that could minimize the 

economic impact for small entities. 

199. Reporting and Certification 

Requirements. The Commission 

considered the level of data collection, 

reporting, and certification, if any, that 

should be required from CMRS 

providers on location-based routing 

issues, weighing the potential burden of 

such requirements on small and other 

entities against the need to ensure 

compliance with the rules. The 

Commission also considered not 

adopting a certification requirement. 

However, absent a certification 

requirement, the Commission and the 

public would have no insight into 

providers’ implementation of locationbased routing. Furthermore, the 

Commission’s ability to easily 

determine whether carriers are in 

compliance would be limited. Another 

alternative the Commission evaluated 

was adopting periodic reporting 

requirements. However, such ongoing 

reporting requirements have the 

potential to overburden providers, 

particularly small entities. Therefore, 

the rules adopted do not contain any 

periodic reporting requirements. We 

believe the one-time certification and 


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live call data reporting requirement we 

adopt will be sufficient for providers to 

demonstrate location-based routing 

implementation. This limited data 

collection best balances the need for 

transparency on compliance with the 

limited ability of some providers, 

particularly small entities, to respond to 

mandatory data collections. The 

adopted certification requirement will 

also help provide important privacy and 

security protections, which we believe 

greatly outweigh any minor burden that 

this requirement might impose on small 

or other entities. 

200. Deferral of Certain Proposed 

Rules and Removal From This 

Rulemaking Proceeding. In the Report 

and Order, the Commission deferred 

taking action on certain rules that were 

proposed in the NPRM. Specifically, in 

the NPRM the Commission proposed 

requiring covered text providers to 

implement location-based routing for all 

911 texts originating on their IP-based 

networks when location information 

meets certain accuracy and timeliness 

requirements. In the Report and Order 

we required CMRS providers to deploy 

and use location-based routing only for 

RTT communications. We deferred 

action on requiring covered text 

providers to deploy and use locationbased routing for other types of text 

messages to 911, such as Short Message 

Service (SMS). The Commission also 

proposed requiring CMRS and covered 

text providers to deliver 911 calls, texts, 

and associated routing information in IP 

format upon request of 911 authorities 

that have established the capability to 

accept NG911-compatible IP-based 911 

communications. To align requirements 

for NG911 services amongst providers 

and avoid confusion among 

stakeholders, we deferred consideration 

of CMRS and covered text provider 

NG911 IP delivery requirements to the 

pending NG911 transition proceeding in 

PS Docket No. 21–479. Our deferral of 

the two proposed requirements above 

eliminated consideration of these rules 

from the current rulemaking proceeding. 

By eliminating these rules from the 

proceeding, the Commission has 

reduced the compliance costs for small 

entities and any related implementation 

burdens small entities may have 

incurred. 

E. Report to Congress 

201. The Commission will send a 

copy of the Report and Order, including 

this FRFA, in a report to Congress 

pursuant to the Congressional Review 

Act. In addition, the Commission will 

send a copy of the Report and Order, 

including this FRFA, to the Chief 

Counsel for Advocacy of the SBA. A 

copy of the Report and Order and FRFA 

(or summaries thereof) will also be 

published in the Federal Register. 

V. Ordering Clauses 

1. Accordingly, it is ordered, pursuant 

to sections 1, 2, 4(i), 10, 201, 214, 222, 

251(e), 301, 302, 303, 307, 309, 316, and 

332, of the Communications Act of 

1934, as amended, 47 U.S.C. 151, 152(a), 

154(i), 160, 201, 214, 222, 251(e), 301, 

302a, 303, 307, 309, 316, 332; the 

Wireless Communications and Public 

Safety Act of 1999, Public Law 106–81, 

47 U.S.C. 615 note, 615, 615a, 615b; and 

section 106 of the Twenty-First Century 

Communications and Video 

Accessibility Act of 2010, Public Law 

111–260, 47 U.S.C. 615c, that the Report 

and Order is adopted. 

2. It is further ordered that the 

amendments to part 9 of the 

Commission’s rules, as set forth in 

Appendix A of the Report and Order, 

are adopted, effective sixty (60) days 

after publication in the Federal 

Register. Compliance will not be 

required for § 9.10(s)(4) and (5) until 

after approval by the Office of 

Management and Budget. The 

Commission delegates authority to the 

Public Safety and Homeland Security 

Bureau to publish a document in the 

Federal Register announcing that 

compliance date and revising 

§ 9.10(s)(6). 

3. It is further ordered that the 

Commission’s Office of the Secretary, 

Reference Information Center, shall 

send a copy of the Report and Order, 

including the Final Regulatory 

Flexibility Analysis, to the Chief 

Counsel for Advocacy of the Small 

Business Administration. 

4. It is further ordered that the Office 

of the Managing Director, Performance 

Program Management, shall send a copy 

of the Report and Order in a report to 

be sent to Congress and the Government 

Accountability Office pursuant to the 

Congressional Review Act, 5 U.S.C. 

801(a)(1)(A). 

List of Subjects in 47 CFR Part 9 

Communications, Communications 

common carriers, Communications 

equipment, Internet, Radio, Reporting 

and recordkeeping requirements, 

Satellites, Security measures, 

Telecommunications, Telephone. 

Federal Communications Commission. 

Marlene Dortch, 

Secretary, Office of the Secretary. 

Final Rules 

For the reasons discussed in the 

preamble, the Federal Communications 

Commission amends 47 CFR part 9 as 

follows: 

PART 9—911 REQUIREMENTS 

■ 1. The authority citation for part 9 

continues to read as follows: 

Authority: 47 U.S.C. 151–154, 152(a), 

155(c), 157, 160, 201, 202, 208, 210, 214, 218, 

219, 222, 225, 251(e), 255, 301, 302, 303, 307, 

308, 309, 310, 316, 319, 332, 403, 405, 605, 

610, 615, 615 note, 615a, 615b, 615c, 615a– 

1, 616, 620, 621, 623, 623 note, 721, and 

1471, and Section 902 of Title IX, Division 

FF, Pub. L. 116–260, 134 Stat. 1182, unless 

otherwise noted. 

■ 2. Amend § 9.3 by adding definitions 

for ‘‘Device-based location information’’ 

and ‘‘Location-based routing’’ in 

alphabetical order to read as follows: 

§ 9.3 Definitions. 

* * * * * 

Device-based location information. 

Information regarding the location of a 

device used to call or text 911 generated 

all or in part from on-device sensors and 

data sources. 

* * * * * 

Location-based routing. The use of 

information regarding the location of a 

device, including but not limited to 

device-based location information, to 

deliver 911 calls and real-time text 

communications to point(s) designated 

by the authorized local or state entity to 

receive wireless 911 voice calls and 

real-time text communications to 911, 

such as an Emergency Services internet 

Protocol Network (ESInet) or PSAP, or 

to an appropriate local emergency 

authority. 

* * * * * 

■ 3. Amend § 9.10 by revising paragraph 

(a) introductory text and adding 

paragraph (s) to read as follows: 

§ 9.10 911 Service. 

(a) Scope of this section. Except as 

described in paragraph (r) of this 

section, the following requirements of 

paragraphs (a) through (s) of this section 

are only applicable to CMRS providers, 

excluding mobile satellite service (MSS) 

operators, to the extent that they: 

* * * * * 

(s) Location-based routing 

requirements—(1) Wireless 911 voice 

calls. (i) By November 13, 2024, 

nationwide CMRS providers must 

deploy a technology that supports 

location-based routing for wireless 911 

voice calls on their internet Protocolbased networks (4G LTE, 5G, and 

subsequent generations of internet 

Protocol-based networks) nationwide. 

At that time, nationwide CMRS 

providers must route all wireless 911 

voice calls originating on their internet 

Protocol-based networks pursuant to the 

requirements of paragraph (s)(3) of this 

section. 


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18524 Federal Register / Vol. 89, No. 50 / Wednesday, March 13, 2024 / Rules and Regulations 

(ii) By May 13, 2026, non-nationwide 

CMRS providers must deploy a 

technology that supports location-based 

routing for wireless 911 voice calls on 

their internet Protocol-based networks 

(4G LTE, 5G, and subsequent 

generations of internet Protocol-based 

networks). At that time, non-nationwide 

CMRS providers must route all wireless 

911 voice calls originating on their 

internet Protocol-based networks 

pursuant to the requirements of 

paragraph (s)(3) of this section. 

(2) Real-time text communications to 

911. By May 13, 2026, CMRS providers 

must deploy a technology that supports 

location-based routing for real-time text 

communications to 911 originating on 

their internet-Protocol-based networks 

(4G LTE, 5G, and subsequent 

generations of internet Protocol-based 

networks). At that time, CMRS 

providers must route all real-time text 

communications to 911 originating on 

their internet Protocol-based networks 

pursuant to the requirements of 

paragraph (s)(3) of this section. 

(3) Timeliness and accuracy 

threshold. (i) Notwithstanding 

requirements for confidence and 

uncertainty described in paragraph (j) of 

this section, CMRS providers must use 

location information that meets the 

following specifications for routing 

wireless 911 voice calls and real-time 

text communications to 911 under 

paragraphs (s)(1) and (2) of this section: 

(A) The location information reports 

the horizontal location uncertainty level 

of the device within a radius of 165 

meters at a confidence level of at least 

90%; and 

(B) The location information is 

available to the CMRS provider network 

at the time of routing the wireless 911 

voice call or real-time text 

communication to 911. 

(ii) When the location information 

does not meet either one or both of the 

requirements in paragraphs (s)(3)(i)(A) 

and (B) of this section, CMRS providers 

must route the wireless 911 voice call or 

real-time text communication to 911 

based on the best available location 

information, which may include but is 

not limited to device-based location 

information that does not meet the 

requirements in paragraphs (s)(3)(i)(A) 

and (B), the centroid of the area served 

by the cell sector that first picks up the 

call, or other location information. 

(4) Certification and reporting. Within 

60 days after each benchmark specified 

in paragraphs (s)(1)(i) and (ii) and (s)(2) 

of this section, CMRS providers must 

comply with the following certification 

and reporting requirements. 

(i) CMRS providers must: 

(A) Certify that they are in compliance 

with the requirements specified in 

paragraphs (s)(1)(i) and (ii) and (s)(2) of 

this section applicable to them; 

(B) Identify specific network 

architecture, systems, and procedures 

used to comply with paragraphs (s)(1)(i) 

and (ii) and (s)(2) of this section, 

including the extent to which the CMRS 

provider validates location information 

for routing purposes and the validation 

practices used in connection with this 

information; and 

(C) Certify that neither they nor any 

third party they rely on to obtain 

location information or associated data 

used for compliance with paragraph 

(s)(1)(i) or (ii) or (s)(2) of this section 

will use such location information or 

associated data for any non-911 

purpose, except with prior express 

consent or as otherwise required by law. 

The certification must state that the 

CMRS provider and any third parties it 

relies on to obtain location information 

or associated data used for compliance 

with paragraph (s)(1)(i) or (ii) or (s)(2) 

have implemented measures sufficient 

to safeguard the privacy and security of 

such location information or associated 

data. 

(ii) CMRS providers also must: 

(A) Collect and report aggregate data 

on the routing technologies used for all 

live wireless 911 voice calls in the 

locations specified for live 911 call 

location data in paragraph (i)(3)(ii) of 

this section for a thirty-day period 

which begins on the compliance date(s) 

specified in paragraphs (s)(1)(i) and (ii) 

of this section. CMRS providers must 

retain live wireless 911 voice call data 

gathered pursuant to this section for a 

period of 2 years. CMRS providers must 

collect and report the following data, 

expressed as both a number and 

percentage of the total number of live 

wireless 911 voice calls for which data 

is collected pursuant to this section: 

(1) Live wireless 911 voice calls 

routed with location-based routing 

using location information that meets 

the timeliness and accuracy thresholds 

defined in paragraphs (s)(3)(i)(A) and 

(B) of this section; 

(2) Live wireless 911 voice calls 

routed with location-based routing 

using location information that does not 

meet the timeliness or accuracy 

thresholds defined in paragraphs 

(s)(3)(i)(A) and (B) of this section; and 

(3) Live wireless 911 voice calls 

routed using tower-based routing. 

(5) Modification of deadlines by 

agreement. Nothing in this section shall 

prevent PSAPs and CMRS providers 

from establishing, by mutual consent, 

deadlines different from those 

established for CMRS provider 

compliance in paragraphs (s)(1)(i) and 

(ii) and (s)(2) of this section. The CMRS 

provider must notify the Commission of 

the dates and terms of the alternate time 

frame within 30 days of the parties’ 

agreement or June 11, 2024, whichever 

is later. The CMRS provider must 

subsequently notify the Commission of 

the actual date by which it comes into 

compliance with the location-based 

routing requirements in paragraph 

(s)(1)(i) or (ii) or (s)(2) within 30 days of 

that date or June 11, 2024, whichever is 

later. CMRS providers must file such 

notifications pursuant to this paragraph 

(s)(5) in PS Docket No. 18–64. The 

parties may not use this paragraph (s)(5) 

to delay compliance with paragraph 

(s)(1)(i) or (ii) or (s)(2) of this section 

indefinitely. 

(6) Compliance dates. Paragraphs 

(s)(4) and (5) of this section contain 

information collection and 

recordkeeping requirements. 

Compliance with paragraphs (s)(4) and 

(5) will not be required until after 

approval by the Office of Management 

and Budget. The Commission will 

publish a document in the Federal 

Register announcing that compliance 

date and revising or removing this 

paragraph (s)(6) accordingly. 

[FR Doc. 2024–03157 Filed 3–8–24; 4:15 pm] 

BILLING CODE 6712–01–P 


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